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Confined Disposal Facility
(CDF) in East Chicago, Indiana
This web page was last updated on February 3, 2003.
This is a (lengthy) letter dated January 16, 2003 to an elected official that details many of The Calumet
Project’s concerns about the Indiana Harbor and Ship Canal Project and related CDF construction project.
Subjects covered include the
the
- economic rationale for the dredging,
- environmental contamination of the Harbor and Canal,
- the flawed nature of the Project,
- construction-related issues,
- groundwater-related issues,
- the unwillingness of the East Chicago Sanitary District to treat water with any level of PCB contamination,
- public health-related issues,
- lack of any consideration of chemical pollutants,
- a discussion of the health effects of naphthalene (which HAS been found at the East Chicago Central
High School air monitoring site), and which specifically effects people from the Mediterranean countries as
well as African-Americans,
- and our Conclusion.
January 16, 2003
Dear Elected Official
We agree with your position on the necessity of cleaning up Lake Michigan.
The Lake is an incredible natural resource of great social, recreational and economic benefit to
Northwestern Indiana and its citizens. We welcome and encourage efforts to clean it up.
Unfortunately, however, the current Indiana Harbor Project is absolutely not the way to address
the problems of the Lake and surrounding areas.
We ask that you act now to halt this Project. Also before beginning, I want to state that a number
of us present have read an incredible amount of the Army Corps of Engineers’ reports and rationales,
specifically including the Final Management Report, the Final Environmental Impact Statement, and
the signed contract between the Corps and the East Chicago Waterway Management Board.
Along with the reports, we have read many of the appendices that supplement the reports. We have a
firm understanding of the Corps’ positions and arguments. In short, our positions are not “emotional”
ones devoid of any logic or rational basis, but are firmly grounded on the Corps’ positions, reports
and actions that we have observed over a number of years.
We can substantiate any claims that we make. 1) Economic Justification. The Project simply is not
designed to address the gross pollution located in the Harbor and Ship Canal: it is designed only
to deepen the Harbor so as to accommodate larger vessels carrying materials for the steel companies,
and any environmental cleanup benefits are “extras”--and the economic rationale for dredging based
on projected shipping amounts are out of date and greatly overstated.
The Corps “final” report for the Indiana Harbor Project is contained within the Chicago District of
the US Army Corps of Engineers and the US Environmental Protection Agency’s Comprehensive Management
Plan, a two volume work.
Volume 1 contains the “Final Feasibility Report and Environmental Impact
Statement,” and is dated January 1999.
Volume 2 contains the appendices to the reports in Volume 1, and particularly contains statements made
in response to the reports in Volume 1.
This Comprehensive Management Plan is the result of a series of processes that are described in Volume
1 (pp. 1-2), and is adopted as the final governing document, as recognized in the signed contract
between the US Army Corps of Engineers and the local sponsor, the East Chicago Water Management District,
an Indiana-state created entity.
The rationale for the Harbor and Canal dredging is to economically benefit two the steel companies,
LTV (now owned by International Steel Group) and Inland (now owned by Ispat), and the Amoco
(now owned by British Petroleum) Oil Company. Amoco/BP is “the only petroleum company which presently
uses the harbor and canal for deep-draft navigation” (p. 2--all references are to Volume 1 unless
specifically stated otherwise).
There has been no dredging in the Harbor and Canal since 1972, and “This is causing deep-draft navigation
difficulties and associated increases in the transportation costs of waterborne commerce” (11). In short,
the problem to be addressed is not environmental pollution, but that the steel companies are suffering for
their inability to use the largest ships possible on the Lakes to ship and receive goods by water.
It is less efficient (and therefore, over time, more costly) for them to ship by smaller craft than larger
ships. As their shipments increase, the accompanying costs escalate, and hence, economic benefits to
dredging the sentiments will only increase. (See also the first paragraph under “Navigation Problems” on
p. 17.)
However, the economic benefit projections of the Final Feasibility Report are based on the assumption “that
the further increase in tonnage delivered is a result of increased demand for steel.” These projections
were made in 1990, and have not been subsequently updated (p. 8).
Thirteen year old projections seem questionable for any substantial project, but seem ludicrous in light of
the overproduction of steel and the on-going consolidation of the industry that has resulted in both
corporations being bought out; LTV after going bankrupt.
In short, the economic need for such dredging is based on outdated and generally suspect projections, which
call into question the very economic rationale for this Project. Despite the economic rationale for the
Project, the Report uses environmental contamination as a reason for the necessity of the dredging, and this
part is convincing--and why the Harbor and Canal need to be cleaned up for ecological reasons regardless of
economic reasons: the Report claims that 100,000 to 200,000 cubic yards of sediment is “loaded” into Lake
Michigan from Indiana Harbor each year, and “The annual sediment load to the lake contains an estimated
67,000 pounds of chromium, 100,000 pounds of lead, and 420 pounds of PCBs” (12).
The Report also discusses a few specific sites of contamination, and specifically noted studies done by
USX that were partially completed in 1993 in part of the Grand Calumet branch that connects to the shipping
canal: “In 36 transects from roughly the USX culvert to the Gary Sanitary District outfall, the
characterization study showed that fully one-third of the 66 samples taken contained PCBs at concentrations
greater than or equal to 500 parts per million.
Sediments were contaminated with PCBs or elevated levels of hazardous wastes at 27 of the 36 transects” (13).
The Report further notes that “Approximately 70,000 CY [cubic yards] of sediments [in the Harbor] are
regulated for disposal under the Toxic Substances Contract Act (TSCA)” (14).
The Report specifically discusses concentrations of benzene, a known carcinogen. They closed that section
by stating, “The sediments represented by benzene exceedence were determined to be ‘presumptively hazardous’
if dredged. The designation ‘presumptively hazardous’ means that upon dredging, these sediments would
require handling in accordance with RCRA Subtitle C, unless further retesting clarified that the sediments
did not exhibit the hazardous waste characteristic of toxicity for benzene.”
Then they begin the following paragraph with: “If these sediments continue to be classified by the US
EPA/IDEM as hazardous, they will not be dredged as part of the Federal navigation project” (16) (emphasis
added). And the report notes that these sediments are so hazardous that “If these sediments are dredged in
the absence of further testing, they will require treatment in accordance with the standards under Subtitle
C of RCRA prior to land disposal” (16).
IF THE PURPOSE OF THIS PROJECT (IN WHOLE OR IN PART) IS TO CLEAN UP THE ENVIRONMENTAL CONTAMINATION OF THE
HARBOR, SHIPPING CANAL AND/OR LAKE, WHY WILL THE BENZENE SEDIMENTS NOT BE CLEANED UP???? Further, if
environmental clean-up is the goal, why does the Corps refused to dredge down to clean sand, and limit
dredging to navigational depths ONLY? (2) Flawed Project.
The site selection process was irretrievably flawed and the construction plans of the CDF are questionable
and have a much larger potential impact on the public than the Corps has suggested. A brief restatement of
the history of the Project might be helpful. The Corps of Engineers has been trying to find a way to dredge
the Harbor and then get rid of the dredged sediments since 1972, when the Clean Water Act made Lake dumping
illegal.
The initial stage envisioned a CDF (Contained Disposal Facility) that would hold dredgings “generated over
a period not to exceed 10 years” (Feasibility Report, p. 20). When that stage was terminated because of the
complexity of related issues, the Chicago District of the Corps began a study in the late 1970s that studied
16 alternative sites for a CDF.
This analysis was based on 10 year CDF design capacity, and the capacity studied for the site selection
study was 1.85 million CY (21). In 1983, they selected four sites for detailed study. [Note: While the
Corps does not specifically delineate the 16 sites, and the map which they present on p. 22 is so inadequate
that one cannot tell with certainty if the ECI site was one of the 16 sites studied, it is absolutely certain
that the ECI site was NOT one of the four sites chosen for detailed study.)
In the 1983 study, they reduced “the 10-year CDF design capacity from 2 million to 1.3 million CY” (21).
Site 12, a lake site southeast of Inland Steel lakefill and east of Jeorse Park in East Chicago was the
preferred location. (A summary of each of the four sites, and reason for site elimination or selection,
is provided on pp. 23-32.)
Public opposition as well as governmental agency dissatisfaction with the Project led to the stopping of
this effort (33). In the late 1980s, the Corps tried yet again. Four potential CDF sites were examined:
this time, without any explanation, the ECI (Energy Cooperative, Inc.) site was included--and this is the
one on which they want to now build the CDF.
However, the Project had been expanded. Also without any explanation provided, the Report notes that in
this series of investigations, “The target CDF design capacity in the third phase of project formulation
was based on a 30-year planning period” (34). It would be made large enough to hold 3 million CY of
dredged material: “This included an estimated 250,000 CY of polluted dredged materials from private or
other related dredging” (34).
Thus, the Project was lengthened from 10 years to 30, and the amount of dredged waste increased from 1.3
million CY to 3 million CY (and would later be expanded to 4.67 million CY). The ECI site is specifically
discussed. It would be constructed of earthen dikes, using off-site materials. No mention of the amount
of truck traffic that would be needed to bring the materials on site, yet for a 90 acre CDF (EIS-11)--the
Corps ultimately decided on a 131 acre CDF (EIS-15) so these figures are obviously low--the Corps reported
that they would need to bring in from off-site, 244,600 CY of clay; 183,500 CY of topsoil; and 244,600 CY
of drainage layer materials.
They also said they would need to import another 66,000 CY of clay (EIS-12). Obviously, a substantial
amount of truck traffic would be needed to bring these volumes of material to the site. Construction-related
issues In the Environmental Impact Statement (EIS), the number of truck trips to import for this material
are estimated:
“Construction and capping materials would probably come by truck over the Indiana Toll Road to 141st Street,
the north on Indianapolis Boulevard to the ECI site.” (Thus, each truck trip would pass by both of the two
schools.) They estimate that 205 truck roundtrips would be made each day of construction. “Stage 1 would
require almost 92,000 total trips over 450 work days during three construction seasons; stage 2 would
involve 28,000 trips over 140 days during a seven month period; and stage 3 would involve 27,000 trips over
130 days during seven months.
Capping would involve 205 trips per day on 250 work days in two construction seasons, totaling 51,250 round
trips” (EIS-79). This importation of clay should be noted, as throughout the Project, the Corps reports
that they will “tie in” the slurry wall that they plan to build around the site to confine groundwater 33
feet deep.
For example, “... a slurry wall around the perimeter of ECI parcels 1, IIA and IIB extending down from the
ground surface down about 33 feet to the stiff clay underlying the site” (EIS-12). In Section 3--Affected
Environment, in the discussion of 3.3. Physical Resources, 3.3.1 Geology/Soil Types, para 3.3.1.1.2, the
Report states, “The northern portion of Lake County lies in an area known as the Calumet Lacustrine Plain.
Sediments in this area consist of fine lake silt and clay ... and clay till of varying thickness and
distribution” (EIS-24). Further, in para 3.3.1.5.1 on ECI Site, they write, “Soil borings drilled to the
northeast of the site indicate approximately 33 feet of sand overlying stiff clay. The underlying soils
on-site are heavily contaminated with substantial quantities of free-phase hydrocarbons.
Estimates of the degree of contamination vary. In July 1990, the site was the source of a substantial oil
spill into the Lake George Branch [of the canal]. Heavy rains caused an estimated 100,000 gallons of
paraffin oil to flow into the canal” (EIS-25).
Yet earlier they reported, “A portion of the dike
material, all of the clay liner material, and all of the topsoil would come from offsite sources” (emphasis
added) (EIS--11 & 12). What seems to be clear here is that the Corps has not done the needed examination
of soils at this site for this Project--we have no idea of how far the soil borings drilled to the northeast
were located from the site, and this is even more questionable for the rest of the 131 acre site--and this
is especially important in light of the questionable quality of the soil on site, which the Corps itself
has reported.
Since this clay is supposedly the base for the slurry wall, it seems important to conclusively know the
thickness and distribution of such clay deposits. And then, even if this clay is present in required
thickness and distribution, then there needs to be extensive testing of whether the clay can support the
additional weight that the Project will add, and that it will then, under stress, maintain its supposed
impermeability.
Without extensive testing under “real” conditions, to build such a depository on such questionable soil
seems almost begging for a disaster. Groundwater It is important to discuss the groundwater situation.
“The Calumet aquifer is an extensive, suficial, thin aquifer formed from the deposited dune, beach, and
lacustrine soils in the Grand Calumet River Basin.
The shallow Calumet aquifer underlies about 10 feet of overburden” (EIS-25). They note (in para 3.3.2.5)
that There appears to be a distinct layer of petrochemical contamination on the surface of the shallow
aquifer in areas around the Indiana Harbor and Canal. The distribution of this layer is not fully
understood.
Past industrial practices and the numerous petrochemical pipelines in the area are possible sources of this
layer. At least two industries (LTV Steel and Amoco Oil) have active programs for reclaiming petrochemicals
from the shallow groundwater within their properties ad use this material as a fuel supplement. This
reclaimed material is characterized as a Number 2 fuel oil (EIS-26).
The Report discusses the specific site. “The groundwater table at and surrounding [the ECI] site is
approximately five feet below the surface. The drainage pattern of the shallow aquifer at this site is
unknown, and may be influenced by the Lake George Branch to the south and pumping by petrochemical
industries to the north and east.”
They state that monitoring wells at the ECI site were the same used for the 141st Street site, and the
monitoring results were discussed in the section on 141 Street. When we go to the relevant para (3.3.2.6.1),
the Report reads, “Monitoring wells in the vicinity of this site were found to have levels of benzene, iron,
phosphorous, ammonia nitrogen, suflate and phenol higher than the average values of other well studied in
the Calumet aquifer...” (emphasis added) (EIS-26).
The CDF is being designed to keep groundwater contamination within the CDF itself. To do this, the Corps
is building a slurry wall around the site so water cannot migrate off-site, and making the bottom slope
downward--this is what they mean by “gradient control system”-- to the site that leads to groundwater
extraction wells.
“Contaminated groundwater collected in connection with the gradient control system would be discharged to
the City of East Chicago wastewater treatment plant for final treat. A pretreatment facility would be
installed on the ECI site to provide initial groundwater treatment, if needed, in order to meet City of
East Chicago pretreatment standards prior to discharging to its wastewater treatment plant” (91).
But the Corps discusses Operations and Maintenance issues for the proposed CDF. I quote extensively from
the section on Gradient Control: It is estimated that removal of 21 million gallons of groundwater from
within the slurry wall would be required to provide an initial 2-foot drawdown and establish the inward
gradient.
It is further estimated that well pumpage averaging 700 gallons per day of groundwater seeping through the
slurry wall would be required to maintain the inward gradient. This maintenance pumping would be required
during the filling of the CDF and the subsequent 30 year RCRA post-closure monitoring period.
An estimated 16 to 17 million gallons would be removed during this period. Infiltration into the groundwater
within the slurry wall will occur due to precipitation. It is estimated that infiltration will average
on-the-order of 36,000 gallons per day per CDF cell [there are three cells planned] prior to placement of
dredged material.
Total infiltration over the life of the project is estimated at about 134 million gallons. This volume of
groundwater will have to be removed from within the slurry wall to maintain the inward gradient.
Precipitation runoff within the CDF during the period of filling is expected to range between 360 and 390
million gallons (93-94).
There simply is no discussion of how these massive amounts of water--where the water table is at five feet,
in an area where the aquifer is polluted with petrochemicals, and all contaminated at a site so bad as to
have an open RCRA status--will be processed, much less a serious discussion of how such water wastes will be
treated and cleaned up.
Nor is there any discussion of how the addition of dredged sediments--including PCBs and Benzene--will effect
this unholy brew of pollution. The Report discusses the need to remove water from the site, and that an “
interceptor sewer” would be connected to the East Chicago Sanitary District sewer lines if treatment was
determined to be necessary” (emphasis added) (40).
In light of the conditions pointed out immediately above, any suggestion that there is any doubt of the need
to treat water from this site indicates a conscious desire to ignore the reality of the site: water on this
site will need extensive treatment under any conditions. The Corps’ plan to pretreat the water and then send
it to the East Chicago Sanitary District elicited a pointed response from the Sanitary District.
In a letter dated March 19, 1996, from Daniel R. Olson, Manager of the Wastewater Division of the East Chicago
Sanitary District to the Corps, the Sanitary District urges the Corps to seek a NPDES permit for direct
discharge into the Lake George Branch of the Canal.
In particular, the Sanitary District specifically responded to the Corps’ statement that the Corps will
“reduce the amounts of PCBs that reach the WWTP (Waste Water Treatment Plant) to a minimum.” The Sanitary
District replied: “PCBs in any concentration shall not be discharged to the collection system.
All wastewater shall be tested for PCBs prior to acceptance by the District. Since laboratory analysis, with
the proper clean up procedures, can take as long as ten days, the water will have to be stored on site and
processed as a batch. This would mean a number of large storage tanks will have to be constructed on site
that would hold about 1.5 million gallons....
Should PCBs be detected in the tank, rinse and decontamination procedures will have to be developed.” The
Corps’ comment on the Sanitary District’s concerns reads: “The content confined disposal facility plan no
longer includes on-site pretreatment and subsequent discharge to the East Chicago wastewater treatment plant.
The current recommended plan provides for complete treatment on the CDF site and discharge directly back to
the Lake George Branch. Final design work will include bench testing to determine the treatment necessary
to allow for discharges directly to the waterway to meet BCC [bioconcentrating chemicals of concern]
requirements.
Final determination of manner of discharge will be made after further coordination with US EPA.” However,
there is simply no discussion of the Sanitary District’s concerns about PCBs, or any other concern noted,
nor are their any plans included in the Comprehensive Management Plan. There is no discussion of
construction of a complete treatment facility on the site, much less any discussion of the construction of
holding tanks and procedures to decontaminate PCBs when found.
In short, despite a pressing need to process and treat a massive amount of severely contaminated water,
and the need to do so to meet stringent clean water act requirements, the Army Corps did not include any
plans in their “final” document published over three years after receiving a strong notification from the
East Chicago Sanitary District of the need to do so. (3) Public Health. This is our greatest concern,
and the one that the Corps seems least interested in.
There is almost no concern about public health. Without any detailed discussion--and only one paragraph
of description of what they included in their table--they present Table 6 on “Environmental/Social Impacts.”
In this one paragraph, they also note that “Further detailed information on these impacts is developed in
the environmental impact statement which follows this report,” and then they report that additional material
can be found for “Taking no Action” (in Volume 2, Appendix C); “Biological Assessment” (2-D); “Environmental
Engineering” (2-F); “Application of Treatment Technologies to Contaminated Sediments” (2-G), and “Dredging
Technologies and Impacts” (2-H) (53).
Note that there is absolutely no discussion of public health impacts, whether on-going, specific or even
potential. When one turns to Table 6, you see that the Corps considered a number of topics, and evaluated
them in several ways, including by site. These topics considered were: geology/soils; groundwater; sediment
quality; water quality; terrestrial communities; threatened endangered species; natural areas and public
lands; archaeological and historic resources; social setting; air quality; aquatic communities; energy
requirements; and one other that can not be made out due to the binding, but appears to be concerned with
contaminated sediments.
Of these, the only one that looks like it could be addressing the impact on people is the category “social
setting.” For the ECI site, the only comments read, “Increased truck traffic resulting from hauling
construction cap materials to the site” (54-55). There is no examination of any public health issues,
which would be pretty amazing in any case, but outrageous in this one: there are two schools--East Chicago
Central High School and Middle School--within 800 yards of the ECI site! The Health and Safety Program that
they propose in the Final Feasibility Report are extremely limited.
The Corps recognizes that “The sediment to be dredged contains chemical compounds in concentrations that
could be harmful to workers either through skin contact or inhalation of released vapors or dusts.
Therefore, an appropriate project safety and health program will be established and implemented.” Then they
make three points: representative sampling and chemicals analysis of sediments will be done, high-volume air
sampling will be conducted to determine “work zones,” “as well as to measure the effect of operations on the
surrounding community,” and personal air monitoring will be maintained (94).
There is no mention of the two schools within 800 yards of the CDF site. The Corps did an “Inhalation Risk
Analysis” to quantify potential air emissions from the site, and here is the first mention--on p. 98!--of any
school, although they mention only the high school and not the middle school. They made some preliminary
risk estimates based on previous data from southeast and southwest Chicago--not Northwest Indiana--and
concluded, based on this extremely questionable data, that “
The emissions estimations predict that the emissions from the CDF operation are slightly higher than emissions
from the ECI site” (99). In the Environmental Impact Statement, they specifically address the issue of risk to
human health (para 4.5.3.4.4) The Report notes that: The US EPA completed a risk analysis for the proposed
CDF at the ECI site....
The study assesses human health risks posed by inhalation of potential airborne contaminants released from
the CDF. The analysis was designed to quantify the potential air emissions of pollutants from the CDF and
obtain the average annual concentrations of pollutants at specific receptors. Due to the exposure of students
and faculty to potential airborne contaminants, a receptor of concern is the high school immediately sought of
the proposed CDF site. (para 4.5.3.4.7)
During the CDF disposal or rehandling operations, air monitoring would be initiated to measure the
significance of volatile and particulate contaminant losses leaving the CDF site. Air monitoring equipment
such as high volume samplers would be located at the perimeter of the site. Monitoring data would be
evaluated to determine if sediment management practices should be altered or amended.
Wind fences covering the sediment, or operational modifications are examples of common control measures that
could be considered. (para 4.5.3.4.8) At this time, the minimum requirement for workers directly in contact
with sediment would be level C personal protective equipment. Personal air monitors would be worn on site to
identify work assignments which pose the highest risk to worker health and safety (emphasis added) (EIS 79-80).
In case it need be said, there is no discussion of risk to students and faculty at the high school, much less
the middle school, even though the Report recognizes the high school as a “receptor of concern.” Key to public
health issues are the chemicals that are to be dredged and/or are present in the air from the open RCRA site.
There simply is no discussion of any such chemical pollutants in any form. In the air monitoring data that I
found on the Corps’ web site, I found a number of chemicals present above reporting levels at East Chicago
Central High School that are listed on the 2001 CERCLA Priority List of Hazardous Substances, as determined by
the Agency for Toxic Substances and Disease Registry (ATSDR). [The list can be found at:
.]
The CERCLA Priority List are those substances most commonly found at facilities on the National Priorities
List (NPL) and which are determined to pose the most significant threat to human health due to their known
or suspected toxicity and potential for human exposure at these NPL sites. As ATSDR notes, “... this priority
list is not a list of ‘most toxic’ substances but rather a prioritization of substances based on a
combination of their frequency, toxicity, and potential for human exposure at NPL sites.”
The hazardous chemicals found by Army Corps air monitors at the East Chicago Central High School that are on
the CERCLA Priority List of Hazardous Substances include lead (2001 rank: #2), Polychlorinated biphenyls
(#5), Benzene (#6), Xylenes (#56), Toluene (#68), Chromium (#76), Naphthalene (#77), Barium (#102), and
Fluorene (#270).
Curious, I then picked one chemical--Naphthalene--to see what I could find regarding its toxicological profile
on the ATSDR site. Dated August 1995, I then downloaded approximately 1” of material on this chemical alone,
along with material on its very similar “cousins,” 1-Methylnapthalene and 2-Methylnapthalene!
.
The toxicological profile is written to provide information for individuals that are or have been exposed to
particular chemicals, and thus is not written to provide information for long-term (i.e., chronic) exposure.
Nonetheless, some idea of the effects of these closely-related chemicals can be found in Section 1, Public
Health Statement, and particular 1.5 “How can Naphthalene, 1-Methylnaphthalene , and 2-Methylnaphthalene
Affect My Health?”
I report only a few of the most trenchant comments: Exposure to a large amount of naphthalene may damage or
destroy some of your red blood cells. [Note: Red blood cells carry oxygen throughout one’s body.] If you
are black or from a Mediterranean country, naphthalene may be more dangerous to you than to people of other
races or nationalities (emphasis added).
These populations have a higher incidence of problems with the enzyme, glucose-6-phosphate dehydrogenase
(G6PD). This enzyme normally protects red blood cells from specific chemical damage created by oxygen in the
air. Exposure to a lot of naphthalene may cause nausea, vomiting, diarrhea, blood in the urine, and a yellow
color to the skin. If you have these symptoms, you should see a doctor quickly. If you are a pregnant woman
and anemic due to naphthalene exposures, there is a good chance that your unborn child will be anemic as well.
Naphthalene can move from your blood to your baby’s blood. Once your baby is born, naphthalene may also be
carried from your body to your baby’s body through your milk. In short, I picked a chemical that is not
particularly high on the CERCLA list, so I didn’t load up on the most extreme. Nonetheless, this chemical is
very toxic, and has been found in Corps’ air monitoring data at over 6 times the high end of the reporting
levels as delineated by the Corps itself! Again, however, there is no mention of the danger of this chemical
or any others in the Corp’s various reports.
In fact, the Corps exhibits qualitatively more concern on the
fate of two peregrine falcons that have been exposed to these hazardous chemicals than to all of the people in
East Chicago combined! But could this be a product of the Corps’ racism? In para 4.5.3.4.9 of the
Environmental Impact Statement, the issue of environmental justice is discussed. After telling all that an
EPA review considered, the Report concluded: “
The analysis concludes that the Comprehensive Management Plan for the Indiana Harbor and Canal Confined
Disposal Facility (CDF) conforms to United States policy of insuring that Federal projects do not
disproportionately impact a community’s right to a safe and clean environment.
The project poses no significant risks to the health of nearby residents or the surrounding environment.
Rather, the project is expected to improve long-term environmental conditions in the Canal, benefiting both
upstream and downstream habitats, and recreational activities that depend on their quality.
In summary, the analysis concludes that the inhabitants of East Chicago , which encompasses a wide spectrum
of income levels and socio-economic backgrounds, will realize cumulative environmental and economic impacts
from the dredging of contaminated sediment from the Canal and the siting of the proposed CDF” (EIS-80).
All that’s missing is a discussion of racial demographics of the area--East Chicago’s population is 87.8%
people of color. CONCLUSION. We have tried to substantiate, based on the Army Corps of Engineers’ own
material--or lack thereof--our claim that this project is irretrievably flawed. We have argued that,
despite any intention you might have had toward cleaning up the Lake, the Corps’ overwhelming interest has
been to deepen the navigation channel of the Canal, and that their expressed interest in the environment is
merely a subterfuge. We further argued that the site selection process was irretrievably flawed and the
construction plans of the CDF are questionable and have a much larger potential impact on the public than
the Corps has suggested.
In making this argument, we have examined construction-related issues and, more importantly,
groundwater-related issues, specifically noting that the water on the CDF site will need extensive treatment
under any conditions, and that the Corps has totally ignored this issue. And finally, we drew your attention
to public health-related issues: the Corps has ignored all-but-totally the fact that there are two schools
within 800 yards of the chosen ECI site.
We have shown there has been no discussion of risk to students and faculty at the high school, much less the
middle school, even though the Report recognizes the high school as a “receptor of concern.” We have
specifically noted they have not provided any discussion of any chemical pollutants concerned in any form,
even though a number of them have been found in Corps air monitoring data above reporting levels at Central
High School, and these chemicals are included on the CERCLA Priority List.
We illuminated the health effects of exposure to naphthalene to give an example of the risks and dangers of
exposure, and to provide data on health affects that the Corps has simply failed to provide. We also pointed
out that the Corps of Engineers has exhibited qualitatively more concern on the fate of two peregrine falcons
that have been exposed to these hazardous chemicals than to all of the people in East Chicago combined.
Without belaboring the point further, we believe the US Army Corps of Engineers has created a massively flawed
project, that has endangered the public health of students and other residents of East Chicago, and they have
refused to address community concerns.
Thank you for your time and consideration.
Kim ScipesExecutive
DirectorThe Calumet Project
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