1. Public Comments Comment: Regarding the management of previous leakage of trichloroethene (TCE) into the environment, I have a number of concerns. Because of the known toxic and carcinogenic properties of TCE and its breakdown products I would like to see what assessments of the health impacts of TCE and its breakdown products were conducted and what protections and precautions were instituted, both inside the facility and for the surrounding community. Workers within the facility are working directly on top of the center of the plume, and Fort Sanders is the most densely populated neighborhood in the city. What are Dow's assessments of the exposure workers and residents are receiving and how has this been communicated to them? If contaminant levels exceed maximum, how will people be informed? Response: The heavy clay soils that exist in the area where the tetrachlocthene (PCE), TCE and breakdown products are located affect the migration of the contaminant. The volatiles tend to adhere to the clays which enable them to retain the contaminants. The groundwater plume has stabilized and is not migrating to the surrounding neighborhood. Rohm and Haas has a Community Action Panel (CAP) that communicates facility conditions to community organizations. According to information provided by the facility, Rohm and Haas (Dow) has their own Exposure Assessment and Control Standard which requires risk assessment and monitoring for hazards with potential health signi?cance and communication of these results to potentially impacted personnel. Comment: I don't feel that these hazards can be accurately assessed for the surrounding community with only one monitoring well outside the plant property and when that well is only checked once a year. I want additional testing sites and shorter intervals between testing. Response: The monitoring well data (analytical results, ?ow rate and direction, and iso- concentration maps) shows that contaminant plumes are stable and not migrating. Data shows that dissolved concentration values measured in groundwater (overburden and bedrock) are either stable or are decreasing in magnitude. In addition, mass and volume of Volatile Organic Compounds (VOCs) are stable or decreasing. The Division of Solid Waste Management (DSWM) required Rohm and Haas to locate additional wells that would be along the downgradient ?ow path from the plant. Rohm and Haas was able to acquire landowner permission for only one off-site well. Rohm and Haas was required by DSWM to sample the well semi-annually. Analytical results showed that the off-site well was not impacted by VOCs and since the plumes are stable and not migrating Rohm and Haas was granted approval to sample the well annually. Comment: I was not here in 2008 for the original permit for remediation, but I would like to know how the decision was made to use solely sodium lactate as the mitigation method. There are many additional mitigation methods available that can be used in place of or in conjunction with the one chosen for this project. These include enhanced bioremediation, subsurface barrier walls, and hydraulic controls. Response: The current permit requires Rohm and Haas to implement a plan for investigating and remediating the contamination at the plant. The sodiiun lactate was used as an Interim Measures to determine its effectiveness as a remedy. The use of sodium lactate is a form of enhanced bioremediation. The facility and their consultant determined the method for remediation with approval as an Interim Measure, and if successful, as a ?nal remedy. The facility consultants were familiar with sodium lactate, have had success with it, at other projects, and made the decision to use this method because it has shown to effectively treat the groundwater. In this case, the use of sodium lactate has shown to effectively treat the groundwater. The ?nal remedy proposed for the site includes the continued injection of sodium lactate and monitoring of plume con?guration. Monitoring data shows that the injections are enhancing the reductive dechlorination (destruction) of PCB based on the following lines of evidence: 0 Degradation products of the injections are observed in both the overburden and bedrock aquifers. The full suite of daughter products was observed from TCE through ethane and ethene. 0 Source area detection of methane and volatile fatty acids indicates reductive biological processes remain active. 0 Deductive dechlorination processes are ongoing. PCE and TCE are minor contributors to groundwater mass within the source area. The facility as a condition of the permit is required to submit corrective action effectiveness reports on an annual basis. Comment: Fort Sanders has grown into the most densely populated area of the city; the people who live here deserve consideration. People do not consent to living in certain neighborhoods on the terms that they may be exposed to hazardous, carcinogenic chemicals. Thousands of people live here because it is where they work, where they go to school, and where they can afford to live. They deserve to know and have some say in what they are being asked to live near and they deserve unquestionable access to clean water, air, and earth. Response: The permit only covers the management of hazardous waste and corrective action. It does not regulate all chemicals at the facility. However, the permit does have a Contingency Plan in place if there is ever an emergency leaks, releases and spills, ?re or explosion). It also has an Inspection Plan in place to inspect the tank and storage facility on a regular basis. The site has an active Community Advisory Panel (CAP) that includes members from various fence line neighborhoods, community organizations, response and regulatory agencies, hospitals, and other local organizations. Members include representatives from the Fort Sanders Neighborhood and the University of Tennessee. The facility will pass information along to the CAP membership committee upon request. In regard to public information regarding releases, the facility has reported to DSWM that the site complies with EPA regulatory requirements regarding the submittal of an annual Toxic Release Inventory (TRI). This information is made public by EPA and can be found at Toxics Release Inventorv Program US EPA. Comment: It is rare to ?nd information about their environmental impact in Knoxville." Dow/Rohm and Haas has a history of spillage, not only in Knoxville but elsewhere. Rohm and Haas, like many chemical companies, has a record nationally. Here in Knoxville violating safety standards as recently as 2016. Storage of hazardous chemicals is invariably dangerous to the public and it requires high levels of public oversight. In Knoxville, the Fort Sanders neighborhood and the workers at the plant were endangered by a spill in 2008, which was never properly cleaned-up. Response: The permit covers the storage of hazardous waste and corrective action of the groundwater. The DSWM hazardous waste staff routinely inspects the facility and has not noted any recent violations of the permit requirements. Inspection reports are available for review at the Knoxville Environmental Field Office. DSWM does not have any information about the 2016 violation but this may have been a violation of a different regulatory program. The permit requires Rohm and Haas to report any spills that occur at the facility. There have been no spills reported that are required by permit conditions. DSWM is not aware of any spill in 2008, however if the commenter has any information please provide the information to DSWM for review. The Rohm and Haas site has had an active CAP that includes members and altemates from various fence line neighborhoods, community organizations, response-"regulatory agencies, hospitals, etc. Members include representatives from the Fort Sanders Neighborhood and the University of Tennessee. The CAP typically meets 9-10 times per year. During those meetings Rohm and Haas discussed various site items of interest including environmental performance and permits. Comment: I ask TDEC to consider, that PCE remains a source of groundwater and air contamination to this day in Fort Sanders, exposing residents to carcinogenic effects. I would encourage TDEC and Rohm and Haas to be more open and communicate with the public about this and advertise their outreach events better. I also urge TDEC to require more frequent and active monitoring of waste storage to prevent future incidents. Please encourage Rohm and Hass to investigate other remediation strategies for future violations since the one they are using is not suf?cient. Response: The data indicate that the remediation strategy is effective and the groundwater plume is not migrating to the Fort Sanders community. The permit has an inspection requirement that requires the facility to inspect the tank and storage facility on a regular basis. The DSWM hazardous waste staff routinely inspects the facility including the facility?s inspection records In order for Rohm and Haas to be more open and communicate with the public, the facility has an active CAP that typically meets 9-10 times per year. For those who want more information pertaining to the facility and want to be involved with the CAP please see the response to Comment 12 for contact information. Comment: I am concerned with the byproducts as a result of bioremediation. Seeing an up and down rather than a decrease in these harmful products including vinyl chloride which is less volatile than PCB and TCE. The document for permit renewal where it shows these chemicals are monitored it shows that the levels are in violation of EPA and maximum contamination levels. Document does not provide any discussion of how they are going to remediate the vinyl chloride. Response: Elevated levels of PCB, TCE and vinyl chloride are being remediated under the corrective action portion of this permit. The permit establishes the clean-up goals for groundwater including vinyl chloride. Vinyl chloride is a daughter product of the break-down of PCB. Groundwater samples collected at the facility indicate the presence of ethane and ethene, which are the end product of PCB reductive dechlorination. The presence of ethane and ethene indicates that vinyl chloride is being degraded at the site due to the enhanced bioremediation. 6 it]. Comment: Rohm and Hass intentionally disposed of carcinogens in groundwater for a period of decades underneath a densely populated college neighborhood simply because there wasn?t a regulation that said they couldn't. Multiple cited exceedances in the amount of waste produced by Rohm and Hass found in water. Response: DSWM has no knowledge of any intentional disposal of hazardous constituents at the facility. However, this permit addresses all groundwater contamination which includes bioremediation, sampling of groundwater, and reporting. Comment: Rohm and Haas, a subsidiary of DOW Chemical for the past decade, will be dealing with thousands of gallons of hazardous waste by storing it in large containers to sit around until transport offsite. Response: The management of hazardous waste is regulated under the requirements of this permit. They are limited to maximum capacity of 7,900 gallons in the tank and 9,900 in container storage. The facility is required to perform daily inspections for the tank and weekly inspections for the container storage area. DSWM performs annual inspections to ensure that the requirements of the permit are met. Comment: Storage itself is another major problem, as old tanks and piping are subject to corrosion and liner failures. The storage tanks on site were manufactured according to 1982 ASME standards, nearly 40 years old. Indeed, at this site there is a corollary issue with containment in that there is remaining cleanup and remediation of chlorinated solvents leaked from previous operations on the site. My concern is that not much has changed with the company?s strategy to deal with hazardous waste despite advances in remediation technology over the past decades. Response: The permit addresses the one hazardous waste storage tank at the facility. The tank, secondary containment, and ancillary equipment are inspected daily when in operation. The tank is coated with corrosion resistant paint and there is a written tank assessment prepared by an engineering ?rm. Any groundwater releases from previous operations are addressed in the Corrective Action Section of the permit. Comment: As a conglomerate that makes over a billion dollars in annual pro?ts, these companies are more than capable of investing the capital into doing full scale, on-site remediation of hazardous waste. That is, using green chemistry and microbiological metabolism to breakdown the volatile waste into inert molecules. Currently, they are storing this waste in tanks and shipping it offsite for processing. Why not invest in cleaner, modern techniques to prevent a future issue, invest in technology and good jobs for workers to perform on-site remediation work for currently produced waste, rather than relying on a strategy leaning heavily on storage, containment, transport, and cleanup after contamination. Response: Rohm and Haas has had the permit for the one hazardous waste storage tank and container storage area for many years. In addition, groundwater remediation has been ongoing for ten years utilizing a method reviewed and agreed on by all parties. The permit application simply incorporates this remediation method as a ?nal remedy.