Question: What is the purpose of the air monitoring stations?
Answer: There are several types of air monitoring being done at the site. The first type of air monitoring is Occupational Safety and Health Administration (OSHA) site worker protection air monitoring, whose pupose is to ensure sire worker safety.
The second type of is construction emissions air monitoring, performed during construction at the work areas. The main focus of this air monitoring is particulate emissions, since Lake County is a non-attainment area for particulates and monitoring is required by IDEM.
The third type of air monitoring is the ambient air monitoring, whose purpose is to gather information on background air quality, prior to the start of construction and dredging. The air monitoring protocols for the ambient air monitoring were developed in consultation with the Indiana Department of Environmental Management (IDEM). The ambient air monitoring results are documented in an annual report; project reports are available on this website.
Air Monitoring / Health Concerns
Question: Why are acceptable air emissions levels not listed on the Corps web page? Why are the air samples being taken only once ever 6 days? Doesn't this mean that the community can be unknowingly exposed to air toxins during the other 5 days?
Answer: There is no set definition of "acceptable air emissions levels." The sampling frequency at the ambient air monitoring stations is consistent with national ambient air monitoring program standards, including IDEM's air monitoring program in northwest Indiana. The purpose of the ambient air monitoring stations is to gather information on background air quality, prior to the start of construction and dredging, and to gether information on air quality during construction and dredging.
Question: Isn't there land available at the ISG site (former LTV site) where the CDF could be constructed?
Answer: A comprehensive site selection process identified many potential locations, and concluded that the former ECI site was the recommended location for the project. This was documented in in the Comprehensive Management Plan (CMP), available locally at the two East Chicago Library branches, at IDEM's Northwest Gary office, and the East Chicago Waterway Management District.
Question: Why won't the entities in charge of the project listen to members of the public with regard to the site? What can the residents who are opposed to the project do to put a stop to placing the CDF at the former ECI site?
Answer: Those working on this porject are committed to listening to an addressing the concerns of the public within the framework of the agencies' authorities and responsibilities, and we are open to suggested ways to improve the project. The feasibility of the project, including identification of sediment storage locations, was studied for nearly 30 years from 1972 when the project was last dredged, to it approval in 1999. The community has been invited to participate in this decision-making process throughout implementation of the project, and the agencies will continue to listen to the views of the public. Those working on the project are committed to completing the project consistent with its overall goals, which are to complete it in a manner that is safe to human health, improves the environment, and is economically beneficial. We encourage the public to work with the agencies to develop the best possible project.
Question: Have the agencies working on the project really listened to community concerns?
Answer: Yes. Specific actions taken on the project as a result of community concerns include:
- Annually reviewing new and emerging technology in the area of removal, transport, disposal and treatment of contaminated sediment.
- Reviewing technologies proposed by the community.
- Establishing long term ambient air monitoring stations at the CDF site and nearby high school.
- Establishing a web page with project information, and posting of the data from long-term perimeter air monitoring stations.
- USEPA completed a supplemental risk analyses. This included having Dr. Louis Thibodeaux complete a literture review of emissions studies, and considering estimated emissions from mechanical and hydraulic CDF operations.
- Holding quarterly community information sessions to provide opportunity for dialogue with the public.
- Completing an evaluation report of property value impacts that can be expected from the project.
Cost-Effectiveness / Project Benefits
Question: How is the cost-effectiveness, that is, the cost-benefit analysis, determined? Can someone explain how this project has economic benefits for the area? What do you consider cost-effective?
Answer: One of the requirements for the Corps to participate in a project is that the economic benefits calculated to result from the project must exceed the project costs. An economic analysis, including a benefit-cost analysis, was completed as part of the feasibility study for the project. It is included as Appendix B in the Comprehensive Management Plan (CMP).
In summary, the economic benefits for this project are based on those derived once the navigational depths at the harbor and canal are restored for commerce. Currently, due to the shallow depths at the navigational channel, ships utilizing the harbor and canal have to "light-load", that is travel without being entirely filled to capacity, thereby increasing the costs of products and materials shipped by water.
While the Corps did not consider the economic value of environmental benefits in its calculation of benefits and costs justifying its participation in the project, environmental benefits of the project were nevertheless quantified as part of the feasibility study, based on a "willingness-to-pay" survery of 1,000 households. Environmental benefits identified by the survey respondents included improved water quality (making it cleaner), improved water for recreational uses such as fishing, swimming and boating, improved wildlife, and improved drinking water.
Question: Why can't the project include dredging down to native material?
Answer: This project was authorized under the Corps' navigation authority. This means that the federal funding that is made available for the project is for dredging the federal harbor and canal only down tto the authorized channel depths, plus an allowance to account for the inaccuracies of the dredging equipment. Much of the contamination that exists at the harbor and canal will be removed with this navigational dredging authority.
In conjuction with other projects, the IDEM, Indiana Department of Natural Resources (IDNR) and U.S. Fish and Wildlife Service (USFWS) will be investigating dredging below the navigation depths. The navigational dredging project is a key component of restoring the watershed's ecosystem for beneficial uses.
Question: What is the dredging method?
Answer: Indiana Harbor and Canal will be dredged mechanically using an "environmental" (closed) clamshell bucket. The sediment will be transported via barge to the CDF, where it will be off-loaded hydraulically (pumped in a slurry). Various dredging and placement alternatives were considered in an economic and environmental analysis performed by the USACE Waterways Experiment Station, and this approach was found to be the least costly as well as to have minimal environmental impacts (including water and air pollution impacts).
Question: Why is it going to take so long to get this project completed?
Answer: The 30-year life of the project relates to the estimated capacity of the CDF for both the backlog and and maintenance dredging, defined below. The backlog dredging is currently scheduled to be completed over a period of 10 years. This may be able to be accelerated based on availability of federal and non-federal funds. The maintenance dredging phase is currently scheduled to be completed over a period of 20 years following completion of the backlog dredging.
Backlog Dredging is dredging of sediment that has collected at the bottom of the harbor and canal since the last time it was dredged in 1972. Removal of the backlogged sediment is expected to provide substantial environmental improvements in terms of reducing that mass of contaminants in the harbor and canal, and in reducing contaminant discharges to Lake Michigan.
Maintenance Dredging is dredging of the sediment that will deposit into the harbor and canal following completion of the backlog dredging, in order to maintain navigable depths at the harbor and canal in the future. This sediment has not yet accumulated in the waterway. The timing of maintenance dredging is generally controlled by the amount of sediment deposits into the waterway, the need to maintain navigation depths, at the availability of funding.
Geology of the Site
Question: Are there caverns located at the CDF site?
Answer: While caverns do not commonly exist in the type of geologic formations that occur in Northwest Indiana, IDEM investigated this question. IDEM staff researched all existing records concerning the former ECI refinery facility. The records included all known engineering drawings, maps, and as-built drawings. No information could be found to conclude that caverns, either naturally occurring or man-made, exist on the former ECI property.
Although it was found that caverns do not exist at the CDF site, IDEM staff contacted a representative of BP/Amoco's Whiting Refinery to discuss the possibility of caverns on the Whiting Refinery prorperty, located norht of the former ECI property. The representative of the Whiting Refinery informed IDEM staff that underground caverns do exist on the Whiting Refinery property. According to the representative of the Whiting Refinery, the underground caverns at the Whiting Refinery are man-made and are located approximately 500 feet below ground surface. One set of caverns is north of Cline Avenue within the Refinery property. Another set of caverns is northwest of the large propane spheres on the south side of 129th Street. The caverns were reportedly dug and piped to house compressed gases such as propane, butane, and natural gas. The caverns were constructed and put into service in the 1980's. The caverns are still reportedly maintained as part of the whiting Refinery.
The caverns are not on the CDF site, and therefore will not affect the CDF.
Question: Is this project hazadous to human health? What is the radius of the human health hazards associated with this project? What standard will be used in determining health risk? Will it include dangers to children, rather than dangers to 25-year old males?
Answer: USEPA evaluated the impacts of the dredging project in a risk assessment for the Environmental Impact Statement, and then expanded upon this analysis in a supplemental risk assessment (SRA). Both assessments found that risks to the community are acceptable. Please see the CMP/EIS and the SRA for additional information.
Question: Who is responsible to provide compensation to people whose health is harmed by the project?
Answer: The question of health concerns resulting from the project can be viewed from two viewpoints.
First is assuring the health and safety of the community at large. The Corps and its non-federal local sponsor are working with the federal and state regulatory agencies to ensure that the project will not adversely affect the health of anyone and no funds are provided for the payment of compensation. However, any individual who believes that they have suffered an injury, including injury to their health, may seek recovery by filing a claim persuant to the Federal Tort Claims Act (FTCA).
Second is the health and safety of those individuals who construct the project. Those individuals are assured a safe and healthy work environment by various contract requirements, which include requiring the contractor to monitor air emissions during construction. Also, the contractor is required to have an approved safety plan, and the contractor is required to carry insurance to protect its workers from work place accidents.
Question: When will the Corps and USEPA review contradictory studies?
Answer: The Corps and USEPA continue to review peer-reviewed studies and data that become available in the field of environmental science. The Corps would be pleased to review any such information that becomes available to us in terms of its applicability to the project. Please provide copies to:
Public Affairs Officer
U.S. Army Corps of Engineers, Chicago District
231 S. LaSalle, Suite 1500
Chicago, IL 60604
Question: Does this project include 9 of the toxins on USEPA's list of 20 most deadly toxins known to man?
Answer: This question appears to be in reference to the Superfund list of substances that are more commonly found at facilities on the National Priorities List (NPL) and which are determined to pose the most significant potential threat to human health due to their known or suspected toxicity and potential for human exposure at NPL sites. Although many of these substances are present in the sediment, the toxicity of these substances is dependent on their concentration as well as the potential for human exposure. The risk assessment completed as part of the Environmental Impact Statement (EIS) indicates that this project represents no significant risk to human health and the environment.
Question: Can USEPA or the Corps determine and provide the results of the cumulative health risks resulting from the health risks of the various individual toxins?
Answer: The risk assessment completed as part of the EIS, as well as the supplemental risk assessment, examined the potential risk associated with a wide variety of contaminants present in the sediment. Although the health risk associated with individual contaminants are calculated separately, the individual results are combined to provide a cumulative health risk. Results of the risk assessment completed as part of the EIS and SRA present cumulative impacts from the various chemicals.
Question: Is this project hazardous to human health, like Thibodeaux's study showed?
Answer: The assertion that Dr. Louis Thibodeaux's study showed the project to be "hazardous to human health" is not accurate. The purpose of Dr. Thibodeaux's study was to complete a review of recent literture in the field of air emissions, and therefore his study did not evaluate whether this project is "hazardous to human health."
Question: Has Professor Thibodeaux's work been taken into account in the supplemental risk assessment work being completed by the USEPA?
Answer: Yes, Professor Thibodeaux's work was completed as part of the supplemental risk analysis effort. Dr. Thibodeaux has had extensive input into the air emission models being used for this project.
Question: What can the community expect in emissions once the project begins? Will the level of contaminant emissions from the project site be higher than the current level of emissions?
Answer: The air emissions from the project site will meet the requirements of the air registration issued by IDEM on June 19, 2002, which specifies maximum extimated emissions levels. The emissions levels during construction and dredging are expected to be within the range of background air emissions levels measured prior to initiating project construction.
Question: Can dredging during colder weather reduce air emissions? Can dredging be suspended when temperatures are high? Can the CDF be covered in order to reduce the amount of air emissions that go into the atmosphere as the sediment dries?
Answer: Although all analysis to date has indicated that the project represents a minimal risk to human health in the community, it is possible that these and other methods may reduce emissions. Therefore the Corps continues to investigate these and other methods, for their consistency with the overall project goals, and for their feasibility for incorporating into the dredging plan.
Question: Will results of recent studies and new technology be taken into consideration?
Answer: Yes, the Project cooperation Agreement includes a provision for periodic review of new and emerging technologies that may be applicable to the project. Information sessions are held annually in April to dicuss new technology in the area of removal, transport, disposal and treatment of contaminated sediment. While currently these new technologies are incompatible with the overall project goals, as new technologies become available that are shown to be safe, effective and economical, it is possible that some may become applicable to this project. The Corps will continue to be on the lookout for such applications. The public is encouraged to forward information to the Corps about new technologies that they may become aware of, so that these can be reviewed and evaluated. The Corps would be pleased to review any information that the citizens provide in terms of its applicability to the project. Please provide copies to:
Public Affairs Officer
U.S. Army Corps of Engineers, Chicago District
231 S. LaSalle Street, Suite 1500
Chicago, IL 60604
Question: What is the status of the East Chicago Waterway Management District (ECWMD)?
Answer: The East Chicago Waterway Management District was created to manage and supervise, in conjuction with other agencies, the industrial, commercial, and recreational development of the waterways in the city in which the district is formed, and to improve the commercial and recreational use of those waterways in an environmentally sound manner. The ECWMD is also the local sponsor for the USACE Indiana Harbor and Canal dredging project, and as such, contributes funding and provides input for the project. Please see the ECWMD website for more information on this agency.
Question: When does the ECWMD Board meet?
Answer: The ECWMD Board meets once a month. On the 3rd Wednesday of every month at 5 p.m. at 4444 Railroad Ave., East Chicago, Ind.
Question: Where can I get additional information?
Answer: Contact the ECWMD at:
4444 Railroad Ave, Suite 110
East Chicago, IN 46312
Phone: (219) 391-8535
You could also see their website for information on this agency (www.ecwmd.net).
Question: Why did the PCB oil get treated in North Carolina?
Answer: Our understanding of the Warren County, North Carolina project is that PCB-laced oils - with levels much higher than those expected to be found in the Indiana Harbor and Canal sediment - had illegally been placed along miles of roadways, and eventually confined at a PCB landfill in Warren County, with the understanding that it would only temporarily be stored there, and that the soils contained at the facility would eventually be treated as state funding became available.
With regards to the Indiana Harbor and Canal dredging project, we are not currently aware of sediment treatment methods that could be incorporated into the project while meeting the overall project goals of completing the work such that it is safe to human health, improves the environment and is economically beneficial. However, the project does incorporate treatment of the sediment pore water and rainfall that will enter the CDF cells, and the groundwater to be drawn down inside of the cutoff wall, prior to its discharge into the canal. The applicability of new and emerging technologies will continue to be evaluated.
Ponded CDF Operations
Question: Why will the Confined Disposal Facility (CDF) be kept ponded?
Answer: The Indiana Harbor and Canal CDF will operate as a two cell ponded facility, without complete dewatering of the dredged material between dredging seasons. As described in the Ponded Decision Memorandum. This method is expected to reduce volatile emissions from the CDF by 40% and eliminate particulate emissions entirely. Ponded operations will also result in construction and operating cost savings and simplify the CDF operation.
Question: Will the CDF blow up or burn? What will happen to the facility in the event of a natural disaster? Is the facility going to be safe?
Answer: The CDF will contain sediment and water, and the flashpoint (the temperature at which this material would spontaneously burst into flames) is greater than 200 degrees Farenheit. This means that esssentially the CDF will not spontaneously burn. The facility includes a wastewater treatment plant and administration building, and these facilities are being designed to current building safety standards. The buildings will include sprinkler systems, alarms, and other modern safety features. The USACE is also coordinating with Lake county, Indiana emergency responders to ensure that they are fully aware of the facility and design, and that any emergency could be safely dealt with. This facility is being designed and constructed to meet or exceed all applicable Federal, State, and Local standards.
Toxic Substances Control Act (TSCA)
Question: Why is the CDF being permitted as a TSCA facility? Will is become a chemical waste landfill?
Answer: Materials containing a concentration of polychlorinated biphenyls (PCBs) higher than 50 mg/Kg are regulated under the Toxic Substances Control Act (TSCA). TSCA was enacted as law by the U.S. Congress in 1976. It prohibits the manufacture of PCBs, controls the phase-out of their existing uses, and sees to their safe disposal. PCBs are the only chemical class specifically named in the Act.
During the Indiana Harbor and Canal project planning phase,documented in the CMP (199), indicated the presence of sediment containing greater than 50 mg/Kg total of PCBs in the federal channel. The sediments with the highest concentration of PCBs occur in two discrete locations of the canal: (1) the most upstream portion of the Calumet River Branch, and (2) along the north bank of the main canal between the Indiana Harbor Belt Railroad and the Pennsylvania Railroad bridges. Collection and analysis of sediment samples at the IHC in 2007 indicated that approximately 60,000 cubic yards of sediment in these locations would be regulated for disposal under TSCA. The maximum PCB concentrations measured in this sampling were 68 mg/Kg.
To comply with federal law, the CDF must be a TSCA permitted disposal facility in order to accept the IHC sediments with elevated PCB concentrations. While the Act also regulates the disposal of industrial chemical waste, the Indiana Harbor and Canal Confined Disposal Facility will not accept chemical waste. The IHC-CDF is for disposal of sediments only.
Placement of TSCA-regulated sediments into the CDF was considered in the Supplemental Risk Assessment conducted by the USEPA in 2006. There is no additional health risk to the community posed by the placement of the TSCA regulated sediments into the CDF.
Real Estate Values
Question: What is the effect of the project on property values, and how long will this effect last?
Answer: A certified real estate appraiser independently reviewed the project, and concluded that the CDF is located so as to minimize any effect on the value of the surrounding properties. The report was distributed at the May 15, 2002 information session, and will be posted on the project web page, accessible from the Corps' website.
List of Acronyms
CDF - Confined Disposal Facility
CMP - Comprehensive Management Plan
ECI - Energy Coorperative, Inc.
ECWMD - East Chicago Water Management District
EIS - Environmental Impact Statement
FTCA - Federal Tort Claims Act
IDEM - Indiana Department of Environmental Management
NEPA - National Envionmental Impact Statement
NPL - National Priority List
OSHA - Occupational Health and Safety Office
PCA - Project Coorperative Agreement
RCRA - Resource Conservation and Recovery Act
TSCA - Toxic Substances Control Act
USEPA - United States Environmental Protection Agency