ENVIRONMENTAL IMPACT STATEMENT
ON THE HUDSON RIVER PCB
RECLAMATION DEMONSTRATION PROJECT
DRAFT
MAY, 1981
VERMONT
MASSACHUSETTS
CONNECTICUT
Long Island Sound
NEW JERSEY
Atlantic Ocean
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
NEW YORK, NEW YORK 10278
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BOY-eE THOMPSON INSTITUTE
PRE DREDGING
1981 and 1982 growing seasons
(May-October)
1. Air Monitoring Near Site 10
1.1 Background monitoring of airborne PCBs in 1981 and 1982
Airborne PCBs will be measured continuously, in duplicate, at one of
the four farm sites near Site 10 in 1981. During this time the sensitivity
of the air monitoring system will be extended more than an order of
magnitude beyond that used by the N.Y. Dept. of Health and confidence
limits will be established for the date at these low levels. A minimum
of 48 samples will be collected in 1981 and analyzed by BTI.
The site for air monitoring will be chosen to coincide as nearly
as possible with the site of the NYDEC weather station.
Airborne PCBs will be measured at all four farms in 1982 using the
best technology as determined in 1981. Minimum of 12 samples per farm.
1.2 Weather Station in 1981 and 1982 .
The maintenance of the PCB air monitoring equipment (Section 1.1)
will include the maintenance and monitoring of the NYDEC weather
station. .
1.3 Technology
1.3.1 In 1981 comparisons will be made between polyurethane foam,
florisil and the new Amber.lite resins. This will be done in conjunction
with Prof. Terry Bidleman as recommended by the PCB Advisory Committee.
1.3.2 PCB contaminated dusts are of public concerra. Therefore a
mobile air sampler will be constructed to measure botfo volatile and
dustborne PCBs in the air. Background neasurements will be made near
Site 10 at the weather station. In addition, the system will be tested
elsewhere (t-;vv ^. I-IMM WMI-I mui^ v^i"1-- -Iii'_v;'h'";i;i77;' ' vr" 'ij"'"1 " "'-h"1; 'j""vVvi 'lj-
A minimum of 16 analyses will "be made (i.e. 4 of
volatile PCBs and A of particulate PCBs at both sites). This work will
be done in conjunction with Prof. Bidleman.
1.3.3 Attempts will be made to evaluate wet and dry deposition rates
of PCBs and the significance of these upon PCB content on foliage
(funded by BTI and possibly by other sponsors). This is necessary to
establish the credibility of airborne PCB monitoring with plant systems.
2. Estimation of Crop Contamination
2.1 Crop Monitoring Near Site 10
Pre-dredging PCB levels in major crops within 3000 m square (approximately
4 square miles) centered around Site 10. 100 plant samples will be
analyzed in 1981 by Raltech, another 150 in 1982. In addition a record
of all crops and their date of harvest will be maintained by BTI along
with appropriate oblique aerial photos taken by BTI.
1981 Raltech 100 samples
1982 " 150 samples
2.2 Data Base for predictions
2.2.1 Pre-dredging PCB levels, in all 13 crops of 'the area will be established
in four test plots, one at each of the farms where continuous air monitoring
will be done in 1982. In 1981 air monitoring will be at only one farm
(Section 1.1) . The data from the 1981 plot (and subsequently from the 1982
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-2-
plots) will allow us to interpolate plant uptake of PCBs from background
levels up to those found at the Patterson Road Dump Site). Most plant
samples (approximately 60 in 1981 and 100 in 1982) will be analyzed by BTI.
1981 Raltech 15
2.2.2 The contamination of all 13 crops at elevated levels of airborne
PCBs will be determined at the Fort Miller Dump Site in the same three
test plots used in 1980 to establish an air-plant relationship for corn,
timothy and alfalfa.
1981 Raltech 30 samples
3. Planning Reclamation of Site 10
The objective is to construct a more productive farm than existed
before the dredge sjoil encapsulation.
Discussions Awit:b>farmers., Ag Extension, and Cornell faculty to present
concepts in sufficient detail that cost estimates can be made.
A. Degree ojf contamination of_I)OT dredge spoil sites
As requested, we will measure PCB levels in grass cover crops at three
dredge spoil sites (Moreau, Buoy 212 and Special Area 13) and recommend
improvements for future maintenance. 15 plant samples will be analyzed
by Raltech.
5. Degree of contamination at Remnant Deposite 3 and 5
As requested, atmospheric PCB levels vill be measured over Remnant Deposit
Sites 3 and 5. In addition, 16 plant samples will be analyzed by Raltech
as a measure of the mean seasonal level in the air.
6. Degree of contamination at Hudson River riffle area near Lock 6
As requested, atmospheric PCB levels vill be measured on the east side
of the Lock 6 riffle area during the siamner when winds are from the vest.
A minimum of six air samples will be analyzed by BTI. Twenty plant
samples (some being aquatic species) vill be analyzed by Raltech as a
measure of seasonal levels of PCBs in the air and in the water.
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June 1/81
June 1/82
May 31/82
May 31/83
BTI Budget
E.H. Buckley (70% NYDEC) 25,820
Lab Asst. (100% NYDEC) 14,000
Part-time Assts. (100% NYDEC) 8,400
Fringe Benefits (14.39%)
Indirect Costs (60.20%)
48,220
6,940
29,030
35,970
1981
48,220
35,970
1981
1982
1982
53,040
39,570
Clerical
Library
Illustrations
Computer
E-M photo room
Greenhouse
Mechanical
Total BTI internal
300
100
200
500
150
900
300
2,450
2,450
2,700
Equipment(mobile air sampler,
power advance) 5,000
Supplies "11,000
External Services (incl.
service contracts) 7,000
Travel(mileage,lodging, meals) 7,000
Telephone . 550
Truck/purchase, modification,
maintenance, insurance) 3,700
Contingency (incl. consultants
& stolen equipment) 5,000
Total BTI external
39,250
39,250
43,170
Total
125,890
138,480
1982 - comparable to 1981 budget but with 10%
inflation factor added.
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f^irJ^Vri-'^^--i^^---^irtflrT«-irii7ff-Tf^aItiJ A-irtir*' L.II nm ffurti ^*^'trirTftMltfmiA-r>ttii>it 11 r-Jrr'_t_mVM
Raltech Samples (Vegetation)
1981 Project 2.1 100 samples
"2.2 45 samples
"4 15 samples
" 5 16 samples
"6 20 samples
Total 196 samples
1982 Project 2.1 150 samples
" 5 16 samples
Total 166 samples
Note: All samples will be freeze-dried and ground
and a subsample (approximately 20 grams)
sent to Raltech.
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BTI Budget June 1, 1981 - May 31, 1982
1981 125,890
1982 125,890 + 10% inflation factor = 138,480
During this period, BTI contributing 14,460 in salaries annually
10,780 in overhead n
1,000 BTI internal cost annually
14,430 BTI external cost in 1981
Total in 1981 - 40,670
Total in 1982 26,240 minimum
Total BTI commitment 66,910 minimum in 1981 &1982
1983 138,480 + 10% inflation factor = 152,330
+ 30,000 addition of chemist with
overhead & supplies = 182,330
1984 182,330 + 10% inflation factor = 200,560
1985 guess of 50,000 unless both air
and plant monitoring required
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DATE:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
MAY 2 1 1981
SUBJECT-. Hudson River PCB Reclamation Project
FROM: Charles Manning, P.E., Chief
Statewide Programs Section, NYWPB
TO: * See'Below
The recently published Federal environmental impact statement (EIS) for
the subject project has recommended approval conditioned on the develop-
ment of short- and long-term monitoring 'programs, operating standards
and procedures, and contingency plans which need to be submitted for
public comment and endorsed by the U.S. Environmental Protection Agency
(EPA) prior to granting final project approval. These programs/plans
need to be developed and distributed for public comment at the EIS public
hearings scheduled -for June 23, 24 and 25, 1981.
To expedite this development process, the New York State Department of
Environmental Conservation (NYSDEC) has requested a meeting/workshop
with appropriate . EPA personnel to present NYSDEC*s program and plan
development concepts and to obtain EPA's comments and recommendations
prior to proceeding'with detailed development.
To assist NYSDEC with its' request, a meeting/workshop has been scheduled
for Thursday, May 28, 1981, at 10:OOAM-in Edison, New Jersey (Building
10-Conference Room). Because of your respective area expertise, your
attendance is requested.
Attached for your information is a copy of the EIS Executive Summary
which describes EPA recommended project conditions (pages 5-10 thru
5-12), and preliminary monitoring program material prepared by NYSDEC.
As additional information from NYSDEC becomes available, it will be
forwarded to you for your review and comment.
If you have any questions with regard to this meeting/workshop or would
like additional information, please call Tom Maher at (212) 264-8958.
Attachment
Addr&.ssees
J. Zelikson, WA
J. Reidy,'ENF-WF
E. Reilly, WA-WS
J. McKenna, SA-RWA
R. Mason, SA-RQA
R. Walka, WA-EI
R. Rohn, WA-EI
EPA Fair-, 1320-6 (Rev. 3-76)
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-2-
C. Massimino, WA-SW
R. Borigiovanni, WA-TR
S. Dorrler, ERT
R. Vaughn, WA-TR .
J. Hudak, SA-MWP /
T. Fikslin, SA-TS*/
"* R. Ogg, AIR-AF
cc: C. Simon, WA
K. Stoller, SA-DD
M. Bonchonsky, ENF-DD
W. Muszynski, WA
D. Sullivan, S&A
J. DeLaura, WA-NY
S. Arella, WA-EI
J. Frisco, SA-HWI
P. Anderson, SA-MWP
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Monitoring Plan Details - Air and Plants
PCB volatilization increases with the PCB concentration in the sediment
or water with the turbulence level in the water and with the temperature.
Dispersion and increased wind speed tends, to lessen the air concentration of
PCB while increasing total emissions. The monitoring plan is based to a large
extent on the probability of having measurable or significant environmental
effects based on previous study data and calculations. A probability table on
this follows. Several items need explanation. These are 8 dams from Troy to
Ft. Edward. The highest PCB water concentrations are likely at the Thompson
Island, Lock 6'and Lock 5 dams. Two studies of gas transfer studies were made
at the Lock 6 dam by USGS. They indicated gas transfer rates at that dam 10 to
20 times as high as for typical pooled river areas. Calculations by Malcolm
Pirnie, Inc. indicated that air emissions from barges or dredges would be
insignificant, <.05 ug/m3 PCB. Due to low turbulence conditions in the quiet
-river water areas, it is also expected the air concentrations will be less than
.05 ug/m3.
From the Malcolm Pirnie, Inc.. 4/7/81 analysis it is expected that under
worst condition of E stability' the Site 10 air concentration would be
0.3 ug/m3 while at the nearest house it would be .2 ug/m3. Thus it assured
that air monitoring for PCB over a central area in the lagoon system surrounded
by water anadownwind of the influent pipe turbulent zone would give higher PCB
levels than at the houses 220-500m away. '
1981 - Background Monitoring
1. Since there is in the near future no access available to Site 10 property
for monitoring studies, background data will be collected from around the site.
Five farms around Site 10 have been selected for plant - air monitoring plots.
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Dr. Buckley of Cornell University will be in charge of this work. On these 4-5
K~
surrounding farms these will be experimental plant plots and air samplers. The
^?
purpose of these samplers will be to access the background air and plant PCB
concentrations before dredging summer and fall 1981. On-one of the farms
closest to the Site there will be a weather station gathering continuously data
for wind speed and direction, relative humidity, solar radiation, air
temperature, barometric pressure and precipitation. Various plants species
will be analyzed for PCB and bi-weekly air samples for PCB correlated with the
I
plant data and weather data. The samples will be analyzed by Dr. Buckley's
laboratory. The summer/ and fall 1981 weather data near Site 10 will be
completed with the Albany and Glens Falls air data and predications raade of
worst case meteorological conditions for the 1982 dredging season.
2. In addition, agricultural crops and vegetation in 2 mile by 2 mile square
area centering on Site 10 wi_ll be sampled twice on a 4'X 4 grid pattern during
the summer and fall. The samples will be analyzed for PCB by Raltech
laboratory. Aerial photographs of the crops will also periodically be taken.
3. In addition, air and plant samples will be taken in the summer and fall in
-&$
the vicinity of Lock 6 dam to access the loss of PCB by river volatilization.
This is to assure that PCB air concentrations at the dam site do not exceed
1 ug/tn-* during dredging and crops abng the river near the dams are not
excessively contaminated by the dredging.
4. In addition, air and plant samples will be taken over remnant deposits 3
tind 5 so that some data will be available by June 22. For paragraphs 3 and 4
plant samples will be analyzed by Raltech and air samples by Cornell
University. A Raltech sample load of 200 to 250 samples per year are planned.
The purpose of the remnant deposit sampling is to assess if air concentrations
could ever be expected to exceed I ug/m^.
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5. Grass samples will be taken from the Buoy 212, SA 13 and.new Moreau
dredging material sites'to determine the PCB level in typical grass grown on a
capped disposal site.
1982-83 During Dredging Plant and Air Related Monitoring
/
Paragraphs 1, 2 and 3 above will be repeated during the dredging years.
The farm plots in paragraph 1 may be reduced from 4 to 2. Forage crop sampling
near Site 10 will increase while sampling in paragraphs 1, 4 and 5 above will
decrease. Two hundred to two hundred fifty plant samples for Raltech.
The weather station will be moved to Site 10 and a continuous air
monitoring station established in the Site 10 area where high PCB
concentrations are expected. There will be continuous air sampling during the
dredging season with a new sample being collected every 24 hours. Several
other samplers will be used as mobile samplers to be moved upwind, downwind or
to nearby houses as needed to verify dispersion predictions in periodic
studies. The DEC lab will have the capability of analyzing 250 air samples
over the dredging season with a 2 day turn around time. Dredging lagoon water
temperature will be recorded daily.
3 Sediment coring and PCB Cs^'' anci pb On the sediment will give the
sediment PCB levels before they are dredged. It is anticipated that 5,000
\v
samples with 10 Cg137 ancj pt, to one peg will be analyzed per dredging
year when after dredging samling is also included. The dredging lagoon
influent percent solids and flow will be measured by recording meter on the
pipeline. By exactly measuring Lite sediment removed from the river, the nature
of the sediment entering the lagoon will be calculated. This will be confirmed
by periodic detailed sampling studies conducted on the lagoon influent pipe
discharge and on the pump out station sediment mixtures. This approach is
selected because it is known from experience that sampling of a dredging
-------
discharge pipe is a very difficult: and imprecise operation. The final lagoon
effluent PCB will also monitored continuously via automatic cpmpositing
samplers operating on a 24 hour cycle. A special sampler to minimize
volatilization losses will be used. Since the lagoon system retention time is
several weeks, soluble PCB will be measured less frequently, typically once or
twice per week. The effluent from the main containment site will also be
sampled continuously. However, frequency of the analysis of these samples for
"total and soluble PCB will depend on site conditions and prior data
correlations available. It is expected that during the hottest months of July
* ^*.
and August that analysis of the containment site effluent would also approach
a daily cycle. One possiblity is that prior air monitoring data and water PCB
data on this containment lagoon, collected at cold-, temperatures will indicate
that there will be no problem with excessive air PCB levels. Another, less
likely possibility, is that~excess air levels will be predicted from early data
and additional more frequent containment area water sampling for PCB will be
done in conjunction with surface treatment of activated carbon, clay or
chitosan addition to the basin to reduce its PCB concentration and resulting
air emissions. The DEC laboratory is anticipating about 200 water PCB analyses
during the dredging season.
In summary, all data on the sediment water, air and weather conditions
form Site 10 will be entered on the computer daily. Projections of future
conditions will frequently be made; so that mitigating measures can be taken
before n \ »i}'./'»^ «' i " level over Silo 10 is re.iched. The I'CIJ in Iho sediment
will be known more than a week before it is dredged. Dredging elutriate tests
conducted in June 1981 wil.l provide data on expected water PCB concentrations.
These will be confirmed by measurement of the lagoon effluent soluble PCB
values.
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1984 Monitoring of Air and Plants After Dredging,, and Site 10, Capping
It is anticipated that paragraphs 2 and 3 dealing with the Lock 6 dam
plant and air sampling and the 4X4 grid sampling of plants and crops around
Site 10 would be continued for 1 year to confirm that plant and air PCB levels
/'
did go down as a result of the completion of the project.
A piped gas collection will be provided for all of Site 10. The rate of
gas flow will be recorded continuouly and PCB concentration will be measured
monthly for 2 years after the capping of Site 10 via funding provided by the
EPA grant. For the first month of operation, the PCB gas samples will be taken
weekly. It is anticipated that the flow of the gas and its PCB concentration
will be low enough to permit discharge to the atmosphere. If this is not the
case, the gas will be treated thru an activated carbon column. ^ >H '
'
^
About 5 grass samples from the Site 10 cap will be analyzed for PCB for
each of the 2 years after the capping.
The three items above in the 1984 programs are all considered essential to
the project and Site 10 and funding by the EPA grant is anticipated. Long terra
monitoring after 2 years after Site 10 capping, is to be funded by DEC. It is
anticipated that the air and 'plant monitoring program will be reduced to
monthly sampling of gas emissions and PCB concentrations during the growing
season, along with groundwater sampling and inspection of the site for any
cracks or slumps in the cap. More details on long term monitoring will be
provided later.
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3. OPERATIONAL CONTROL AND MITIGATION PROGRAM
The air sampling program previously described will provide a "real time"
assessment of air quality both at the containment site as well as the nearest
sensitive receptors. The air quality analysis performed by Malcom Pirne Inc.,
indicates that concentrations at the nearest receptor are approximately 30
percent less than concentrations at the site, under worst atmospheric
conditions, (i.e. E-stability, low wind speed).
As previously reported, under the worst case scenario, concentrations at
the nearest receptor (200m) have been computed to be .0.2(f ug/m^, (1)
substantially less than the New York State Department of Health recommended
24-hour average concentration of 1.0 ug/m^.
In an effort to minimize losses of PCS due to volatilization, several
design features have been employed. First, the containment area has
incorporated a central dike which reduces the exposed water surface area and
consequent emissions by approximately 50 percent. Secondly, the most
contaminated sediment will be placed in the easter most cell of the containment
area, hence increasing the distance to the nearest receptor.
Another design feature will be to schedule the Hot Spot removal according
to PCB concentration. If clamshell dredging is used in the Thompson Island
Pool, two dredges will be required. If one dredge is working in an unusually
hot area, the other will be directed to a below average area so that higher
concent nit ion will be diluted at the disposal site.
If hydraulic dredging is used this averaging will not occur as only one
hydraulic dredge is required. However, now that the project has been reduced
in scope to $26.7 million, clamshell dredging appears to be the preferred
alternative for reasons that are discussed more fully in our rescoping report.
(1) Malcolm Pirnie, Inc., A/2/81
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One operational measure' to minimize losses of PCB due to volatilization
which will be routinely performed is to cover exposed sediment in the
containment area with a high-organic content mulch. This material will be
applied to sediment as it becomes exposed/ The PCB will become adsorbed to the
organic material, hence preventing; its loss to the atmosphere. As the exposed
sediment attains structural stability a more rigorous intermediate cover will
be emplaced. Upon completion of each dredging season a clay cap will be placed
on the entire site.
In the event that air concentrations at the containment site approach
levels recommended by the NYS Department of Health (1.0 ug/tn^) for the
nearest receptor, several mitigating measures are available to decrease the
level of soluble PCB in the containment area, roughing and storage pond and the
water treatment plant. Site air levels of PCB will be predicted using the
known values of influent concentrations, meterological conditions and basin
water concentrations. Various measures can be implemented depending on the
projected meterological conditions.
The mitigating measures to be employed are described below:
Air Quality Assurance
Volatilization i£ in part a function of the exposed surface area and water
column concentration. Various measures may be employed to reduce or mitigate
volatilization at the site. Based on continuous air quality data collected
should air concentrations at the site exceed 1.0 ug/m^t during critical
nieterolgical conditions, powdered activated carbon (L'AC) may be applied to the
surface of all basins. The activated carbon has a very high surface area to
mass ratio and has been demonstrated to possess a high potential for adsorbing
PCB. The application procedure will feature a hopper storage facility, a
slurry storage tank and a hose application system. Also, to minimize
turbulence, the influent to the containment area will be temporarily ceased and
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one flash board will be added to the exit weirs of all units. This will insure
that a quescent condition is maintained on .all water bodies, hence optimizing
the coverage and effectiveness of carbon application.
An alternate adsorbent which could be utilized is chitosan, a manufactured
/
by the Kypro Company. Chitosan is derived from shell fish components and is
utilized as an adsorbent. Application rates would be similar to activated
carbon. Material handling problems would be somewhat alleviated utilizing this
substance.
The application of adsorbents will continue until such time as ambient air
PCB concentrations at the containment site are reduced below the New York State
Department of Health recommended ,a 24-hour air concentration of PCB of
3
1.0
Concurrent with this adsorbent additions, dredging may be halted during
- --- """'
these critical conditions. Each action will be taken on an as needed basis to
insure standard compliance.
It should be noted that the ambient air data collected will be recorded
and made available for public perusal on a routine basis. Should the need for
implementation of contingency -plans occur, the New York State Department of
Health and the Regional Office of the New York State Department of
\^
Environmental Conservation will be consulted and involved in the decision
<~
making process.
Livestock and Feed Crop Protection
Previous studies in the vicinity of PCB-contaminated landfill sites
indicate that contamination of forage crops is limited to 700m of the landfill
sites. Volatilization of PCBs from the dredge spoils may increase levels in
crops and grazing forage near the site. Based on projections, vegetation will
be monitored within 2000m of the site or to a distance where PCB levels are
below the FDA maximum allowable level of 0.20 ug/g.
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In the event that the crops and grazing forage exceed FDA limits due to
PCB volatilization from the containment site, inventories of contaminated crops
will be made, a replacement value will be computed based in consultation with
r /
the NYS Department of Agriculture and Markets and local farm agencies and full
reimbursement will be made to the owner of the crops. Contaminated crops will
be harvested by the farmer and become the property of New York State.
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Research and Monitoring Plan-Index
Total Budget - 5 Years
Agency and Study Manager
DEC, Bureau of Water
Research, Dr. Tofflemire
DEC, Bureau of Water
Research, Dr. Tofflemire
DF.C, Boyce Thompson,
and other experts
DEC, Bureau of Water
Research
Y
' N
p
DEC, Bureau of Water
Research
DEC, Bureau of Water
Research, Dr. Tofflemire
DF.C, Bureau of Water
Research, Mr. Ryan
DEC, Bureau of Env. Pro-
_t£ction, Dr. Horn, Dr.Sloan
NYS Dept. of Health,
Dr. Simpson
USCS, Albany,
Dr. Schroeder
^- Doyce Thompson Institute,
Dr. Buckley
_. DEC, Bureau of Water
Research and Doyce Thompson
Inst itute
Univ. of Michigan,
Dr. Rice
Study Task
Coring, fathometry preci-
sion dredging monitoring
Monitor sediment erosion
and burial
Air Monitoring for PCB
Site 10 operation aji
^return flow.fjnd near
idredge monitoring
Step I Grant
$227,410
Site 10 ground water and
sampling and water balance
Annual technical seminars
and reports and photographs
'Project Laboratory for sedi-
ment, water and air analyses
A. Long-term fish PCB trends
x
J}. Near dredge fish PCB trends
A. Long-term macroinvertebrate
trends
B. Near dredge macroinver-
tebrate trends
Water and sediment PCB trans-
port, water supplies
10,000
269,955
75,000
50,000
65,000
Plant PCB trends, Air PCB trends 45,000
Wetlands mapping, photography
and changes
Rates of PCB desorption
from bottom sediments
Total
$ 400,000
Grant
Other Funds
$ 5,000 DEC
« ---- to be determined)
50,000*
40,000 to be determined
20,000 DEC
350,000
350,000 175,000 DEC
(to be determined)
100,000 DEC
50,000
250,000
(to be determined)
250,000 USGS
50,000
50,000
5,000 DEC
2,500 Univ.
of Mich.
Time Frame
2 1/2 yrs, 1981-
82, 83
5 yrs
5 yrs
2 yrs, 1982-83
5 yrs
5 yrs
2 1/2 yrs, 1981,
1982-83
5 yrs
1 yr, 1982
5 yrs
1 1/2 yrs, 1981-
82
5 yrs
5 yrs
3 yrs, 1981,
19U2-83
2 yrs, 1981-82
* Integratedinto dredging administration costs.
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Probability Summary Relative to Plant and Air Monitoring
Crops exceed .2 ppm
Air exceeds 1.0 ug/m
Crops exceed .2 ppm
Air exceeds 1.0 ug/m
On Site 10 -700m Site 10 +700m Site 10 Lock 6 Dam Area Remnant Deposits 3 and 5
P
N
I
£ A.
NA N
N N
PDA
N L N
x I N I
_P
N
I
D
N
I
*
N
I
p
L
N
. £
L
N
A
NL
N
P
NA
N
D
NA
N
A_
N
I
-700M Remnant Depos.its
_P u_ A_
L - L - N
area 5 area 5
Hot Spots in River
Barges &' Dreges
NA NA NA
N
N
I=Impossible, N=Not likely, L=Likely, V=Very likely, NA=Not applicable or no crops, P=Present conditions,
D= During Dredging, A=After Site 10 and remnant capping.
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2. ENVIRONMENTAL MONITORING PROGRAM
Background
The Hudson River sediments were contaminated with PCB and other
pollutants. This has resulted in a great loss to the fishery in the Hudson
River and some problem for water supplies and plants near dump sites or dans.
A thorough program involving dredging of the high PCB sediments (hot spot
>50 ppm) from the upper Hudson and burial of the sediments in a secure site
and eventual detoxification of PCB is recommended. The remedial program and
data are described in Technical Papers 51 and 55 and in the EIS for the
Project. Over the past several years there has been several million dollars
of research, monitoring and engineering studies, relating to PCB in the Hudson
River that were authorized by our PCB Advisory Committee.
Purpose and Scope r-
The purpose of this Monitoring and Research Plan (MRP) is to measure
the true effect of the remedial measures on the environment. Thus the MRP is
more specific and applied from the previous studies and is designed to
document how well the project achieves its projected benefits and prevents or
causes any secondary adverse impacts. The area covered includes both the
upper Hudson (Ft. Edward to Troy) and lower Hudson (Troy to New York City).
Some studies such as fish and water monitoring are designed for a 5 year
duration to be able to show true after dredging effects, while others are
designed for only the immediate 1-2 yrs immediately surrounding the dredging
event. The budget was originally specified at 10% of the project grant
funds. Both the 1-2 year studies and the 5 year studies are needed to show
the major effects of the project on the environment.
MRP Development and Management
The MRP was developed by the scientific subcommittee of the PCB Advi-
sory Committee and sent out for review and comments in November 1980. Dr.
James Tofflemire is acting as the coordinator for the MRP under the direction
of James Dezolt the PCB Project Manager, Italo Carcich, the Director of the
Bureau of Water Research, the PCB Advisory Committee and EPA Region 2.
Organization and Index
On the following table the various research and monitoring tasks are
indexed. For each task there follows a more detailed description of the work
for that task. Those hudj'.et items Ur.le.il under the SI c|> 1 Grant are for
deloir dredj'iii}' moil i tor in)'.. Sonic n| (lit- detail:; "I I lie diiriiij', and alter
il red)1, i II}', iiii>u i t or i it}', ;ire still to l><: worked out. Siudir:; on this project's
effects beyond 5 years, are considered long-term monitoring, not to be funded
by the EPA grant.
-------
Monitoring Plan Details - Air and Plan:s
PCB volatilization increases with the PCB concentration in the sediment
or water, with the turbulence level in the water and with the temperature.
Dispersion and increased wind speed tends to lessen the air concentration of
PCB while increasing total emissions. The monitoring plan is based to a large
extent on the probability of having measurable or significant environmental
effects based on previous study data and calculations. A probability table on
this follows. Several items need explanation. These are 8 dams from Troy to
Ft. Edward. The highest PCB water concentrations are likely at the Thompson
Island, Lock 6 and Lock 5 dams. Two studies of gas transfer studies" were made
at the Lock 6 dam by USGS. They indicated gas transfer rates at that dam 10 to
20 times as high as for typical pooled river areas. Calculations by Malcolm
Pirnie, Inc. indicated that air emissions from barges or dredges would be
insignificant, <.05 ug/m3 pCB. Due to low turbulence conditions in the quiet
river water areas, it is also expected the air concentrations will be less than
.05 ug/m3.
From the Malcolm Pirnie, Inc. 4/7/81 analysis it is expected that under
worst condition of E stability the Site 10 air concentration would be
0.3 ug/m-' while at the nearest house it would be .2 ug/m3. Thus it assured
that air monitoring for PCB over a central area in the lagoon system surrounded
by water and downwind of the influent pipe turbulent zone would give higher PCB
»
levels than at the houses 220-500m away.
I('MI - H,'ii'k)'.rnini(l MOII i I or iii)',
1. Since there is, in the miar future, no access available to Sitt; 10
property for monitoring studies, background data will be collected from around
the site. Five farms around Site 10 have been selected for plant - air
monitoring plots. Dr. Buckley of Cornell University will be in charge of this
-------
work. On these 4-5 surrounding farms these will be experimental plant plots
and air samplers. The purpose of these samplers will be to access the
background air and plant PCB concentrations before dredging summer and fall
1981. On one of the farms closest to the Site there will be a weather station
gathering continuously data for wind speed and direction, relative humidity,
solar radiation, air temperature, barometric pressure and precipitation.
Various plants species will be analyzed for PCB and bi-weekly air samples for
PCB correlated with the plant data and weather data. The samples will be
analyzed by Dr. Buckley's laboratory. The summer and fall 1981 weather data
near Site 10 will be correlated with the Albany and Glens Falls air "data and
predications made of worst case meteorological conditions for the 1982 dredging
season.
2. In addition, agricultural crops and vegetation in 2 .mile by 2 mile square
area centering on Site 10 will be sampled twice on a 4 X 4 grid pattern during
the summer and fall. The samples will be analyzed for PCB by Raltech
laboratory. Aerial photographs of the crops will also periodically be taken.
3. In addition, air and plant samples will be taken in the summer and fall in
the vicinity of Lock 6 dam to access the loss of PCB by river volatilization.
This is to assure that PCB air concentrations at the dam site do not exceed
1 ug/m^ during dredging and crops along the river near the dams are not
excessively contaminated by the dredging.
4. In addition, air and plant samples will be taken over remnant deposits 3
.Mid !) no dial some
-------
5. Grass samples will be taken from the Buoy 212, SA 13 and new Moreau
dredging material sites to determine the PCS level in typical grass grown on a
capped disposal site.
1982-83 During Dredging Plant and_ Air Related. Moni tor ing
1 Paragraphs 1, 2 and 3 above will be repeated during the dredging years.
The farm plots in paragraph 1 may be reduced from 4 to 2. Forage crop sampling
near Site 10 will increase while sampling in paragraphs 1, 4 and 5 above will
decrease. Two hundred to two hundred fifty plant samples for Raltech.
The weather station will be moved to Site 10 and a continuous air
v,
monitoring station established in the Site 10 area where high PCB
concentrations are expected. There will be continuous air sampling during the
dredging season with a new sample being collected every 24 hours. Several
other samplers will be used as mobile samplers to be moved upwind, downwind or
to nearby houses as needed to verify dispersion predictions in periodic
studies. The DLC lab will have the capability of analyzing 250 air samples
over the dredging season with a 2 day turn around time. Dredging lagoon water
temperature will be recorded daily.
Sediment coring and PCB Cg137 and pb on the sediment will give the
sediment PCB levels before they are dredged. It is anticipated that 5,000
samples with 10 Cg^' and Pb to one PCB will be analyzed per dredging
year when after dredging samling is also included. The dredging lagoon
influent percent solids and flow will be measured by recording meter on the
|i i pc I i iu%. lly i-x.'U'lly measuring, t lir scil imriit n-mnvrcl limn the river, llic n;ilmv
c
of the sediment entering the lagoon will be calculated. This will be confirmed
by periodic detailed sampling studies conducted on the lagoon influent pipe
discharge and on the pump out station sediment mixtures. This approach is
selected because it is known from experience that sampling of a dredging
-------
discharge pipe is a very difficult and imprecise operation. The final lagoon
effluent PCB will also monitored continuously via automatic compositing
samplers operating on a 24 hour cycle. A special sampler to minimize
volatilization losses will be used. Since the lagoon system retention time is
several weeks, soluble PCB will be measured less frequently, typically once or
twice per week. The effluent from the main containment site will also be
sampled continuously. However, frequency of the analysis of these samples for
total and soluble PCB will depend on site conditions and prior data
correlations available. It is expected that during the hottest months of July
and August that analysis of the containment site effluent would also approach
a daily cycle. One possiblity is that prior air monitoring data and water PCB
data on this containment lagoon, collected at cold temperatures will indicate
that there will be no problem witli excessive air PCB levels. Another, less
likely possibility, is that excess air PCB levels will be predicted from early
data and additional more frequent containment area water sampling for PCB will
be done in conjunction with surface treatment of activated carbon, clay or
-chitosan addition to the basin to reduce its PCB concentration and resulting
air emissions. The DEC laboratory is anticipating about 200 water PCB analyses
during the dredging season.
In summary, all data on the sediment, water, air and weather conditions
from Site 10 will be entered on the computer daily. Projections of future
conditions will frequently be made; so that mitigating measures can be taken
before a I ug/m^ air level over Site 10 is reached. The PCB in the sediment
*.
will In- known muic ill/in ;i week In1 I ore il is >, < I ul r i ;it .1: ti'Rlfl
conducted in June 1981 will provide data on expected water PCB concentrations.
These will be confirmed by measurement of the lagoon effluent" soluble PCB
values.
-------
1984 Monitoring of Air and Plants After Dredging^ and Site 10^ Capping
It is anticipated that paragraphs 2 and 3 dealing with the Lock 6 dam
plant and air sampling and the 4X4 grid sampling of plants and crops around
Site 10 would be continued for 1 year to confirm that plant and air PCB levels
did go down as a result of the completion of the project.
A piped gas collection will be: provided for all of Site 10. The rate of
gas flow will be recorded continuouly and PCB concentration will be measured
monthly for 2 years after the capping of Site 10 via funding provided by the
EPA grant. For the first month of operation, the PCB gas samples will be taken
*t
weekly. It is anticipated that the flow of the gas and its PCB concentration
will be low enough to permit discharge to the atmosphere. If this is not the
case, the gas will be treated thru an activated carbon column.
About 5 grass samples from the Site 10 cap will be analyzed for PCB for
each of the 2 years after the capping.
The three items above in the 1984 programs are all considered essential to
the project and Site 10 and funding by the EPA grant is anticipated. Long term
monitoring after 2 years after Site 10 capping, is to be funded by DEC. It is
anticipated that the air and plant monitoring program will be reduced to
monthly sampling of gas emissions and PCB concentrations during the growing
season, along with groundwater sampling and inspection of the site for any
cracks or slumps in the cap. More details on long term monitoring will be
provided later.
-------
Probability Summary Relative to Plant and Air Monitoring
Crops exceed .2 ppm
Air exceeds 1.0 ug/m
Crops exceed .2 ppm
Air exceeds 1.0 ug/m3
On
P
N
I
Site 10
D
NA
N
-700M
A
N
N
Remnant
-700m
_P
N
I
Depos
Site
D
L
N
its
10 +7GOm Si
A P_
N N
I . I
Hot Spots
Barges &
D
N
I
te 10
A
N
I
Lock 6 Dam Area
PDA
L L NL
N .N N
Remnant Deposits
P D
NA NA .
:: N
3 and 5
.A
N
I
in River
Dredges
L - L - N
area 5 area 5
NA"
_D
NA
A
NA
N
N
I=Impossible, N=Not likely, L=Likely, V=Very likely, NA=Not applicable or no crops, P=Present conditions,
D= During Dredging, A=After Site 10 and remnant capping.
-------
Research and Monitoring Plan'Index
i
Agency and Study Manager
DEC, Bureau of Vater
Research, Dr. Toffienire
DEC, Bureau of Water
Research, Dr. Toffleaire
DEC, Boyce Thompson,
and other experts
DEC, Bureau of Water
Research
DEC, Bureau of Water
Research
DEC, Bureau of Water
Research, Dr. Tofflemire
DF.C, Bureau of Water
Research, Mr. Ryan
DEC, Bureau of Env. Pro-
tection, Dr. Horn, Dr. Sloan
NYS Dept. of Health,
Dr. Simpson
USC'S, Albany,
Dr. Schroeder
Boyce Thompson Institute,
Dr. Buckley
DEC, Bureau of Water
Research and 3oyce Thompson
Inst itute
Univ. of Michigan,
Dr. Rice
Study Task
Coring, fathonetry preci-
sion dredging monitoring
Monitor sediment erosion
and burial
Air Mani taring .for PCS
i* '
Total Budget - 5 Years
Step 1 Grant Total Grant
$227,410
Site 10 operation and
return flow, and near
dredge monitoring
Site 10 ground water and
sampling and water balance
Annual technical seminars
and reports and photographs
Project Laboratory for sedi-
ment, water and air analyses
A. Long-term fish PCB trends
B.. Near dredge fish PCB trends
A. Long-term mac roinvertebrate
trends
B. Near dredge macroinver-
tebrate trends
Water and sediment PCB trans-
port, water supplies
10,000
269,955
75,000
50,000
65,000
Plant PCB trends, Air PCB trends 45,000
Wetlands mapping, photography
and changes
Rates of PCB desorption
from bottom sediments
$ 400,000
Other Funds
$ 5,000 DEC
50,000*
40,000
to be determined
20,000 DEC
350,000
350,000
(to be determined)
50,000
250,000
175,000 DEC
100,000 DEC
50,000
50,000
250,000 USCS
/©<^<»<3 BTI
5,000 DEC
2,500 Univ.
of Mich.
Ti-.e Fr.iT.^
2 1/2 yrs, l«Jal-
82, 83
5 yrs
5 yrs
2 yrs, 1982-83
5 yrs
5 yrs
2 1/2 yrs, 1981,
5 yrs
1 yr, 1982
5 yrs
1 1/2 yrs, 1981-
82
5 yrs
5 yrs
3 yrs, 1981,
19U2-83
2 yrs, 1V81-S2
* Integrated into dredging administration costs.
-------
^ j
2. ENVIRONMENTAL MONITORING PROGRAM
Background .. ^ ^ c>.^.
The Hudson River sediments were,, contaminated with PCB and other
pollutants. This has resulted in a great loss to the fishery in the Hudson
River and some problem for water supplies and plants near dump sites or dans.
A thorough program involving dredging of the high PCB sediments (hot spot
>50 ppm) from the upper Hudson and burial of the sediments in a secure site
and eventual detoxification of PCB is recommended. The remedial program and
data are described in Technical Papers 51 and 55 and in the EIS for the
Project. Over the past several years there has been several million dollars
of research, monitoring and engineering studies relating to PCB in the Hudson
River that were authorized by our PCB Advisory Committee.
Purpose and Scope r
The purpose of this Monitoring and Research Plan (MRP) is to measure
the true effect of the remedial measures on the environment. Thus the MRP is
more specific and applied from the previous studies and is designed to
document how well the project achieves its projected benefits and prevents or
causes any secondary adverse impacts. The area covered includes both the
upper Hudson (Ft. Edward to Troy) and lower Hudson (Troy to New York City).
Some studies such as fish and water monitoring are designed for a 5 year
duration to be able to show true after dredging effects, while others are
designed for only the immediate 1-2 yrs immediately surrounding the dredging
event. The budget was originally specified at 10% of the project grant
funds. Both the 1-2 year studies and the 5 year studies are needed to show
the major effects of the project on the environment.
MRP Development and Management
The MRP was developed by the scientific subcommittee of the PCB Advi-
sory Committee and sent out for review and comments in November 1980. Dr.
James Tofflemire is .acting as the coordinator for the MRP under the direction
of James Dezolt the PCB Project Manager, Italo Carcich, the Director of the
Bureau of Water Research, the PCB Advisory Committee and EPA Region 2.
Organization and Index
On the following table the various research and monitoring tasks are
indexed. For each task there follows a more detailed description of the work
for that task. Those budget items listed under the Step I Grant are for
before dredging monitoring. Some of the details of the during and after
dredging monitoring are still to be worked out. Studies on this project's
effects beyond 5 years, are considered long-term monitoring, not to be funded
by the EPA grant.
-------
\
\
EPA
MAY 04 IS 81
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
NEW YORK. NEW YORK 10278
To All Interested Government Agencies and Public Groups:
This is to inform you that the draft Environmental Impact Statement (EIS)
on the Hudson River PCS Reclamation Demonstration Project is available for
public review and comment at the following locations:
New York State Department of
Environmental Conservation
21 South Putt Corners Road
New Paltz, New York
New York State Department of
Environmental Conservation
2 World Trade Center
New. York, New York
1. Crandall Library 2.
City Park
Glens Falls, New York
3. New York State Department of
Environmental Conservation 4.
202 Mamaroneck Avenue
White Plains, New York
5. New York State Department of
Environmental Conservation
50 Wolf Road
Albany, New York
This draft EIS was prepared by the U.S. Environmental Protection Agency
(EPA), Region II with the assistance of WAPORA, Inc. an environmental
consultant. The document is in accordance with the regulations published
under the National Environmental Policy Act. The U.S. Army Corps of
Engineers and the New York State Department of Environmental Conservation
(NYSDEC) have acted as cooperating agencies in the preparation of the
document.
This draft EIS is based on information presented in the draft State Envi-
ronmental Quality Review Act EIS and supporting documents prepared by
NYSDEC and its consultants. This EIS has evaluated the proposed Hudson
River PCB Reclamation Demonstration Project from the standpoint of public
health, environmental impact, cost, and engineering feasibility. As a
result of these analyses, EPA recommends that an action alternative be
implemented. The full scale action alternative, estimated at approximately
$43 million dollars, has been determined to be the most desirable project
in terms of potential beneficial impacts. However, since the full scale
project may not be realized unless additional funds are obtained by NYSDEC,
the reduced scale project is also recommended.
As a part of the action alternative the development of a monitoring program
is recommended to demonstrate any improvement in the rate of recovery of
the Hudson River and the feasibility of the indefinite storage of PCB
contaminated sediments in an upland containment site.
EPA has determined that this action, with the mitigation measures discribed
in the EIS, will not endanger public health, safety, and welfare.
US EPA Region 2 Library
290 Broadway. 16th Floor
New York, NY 10007
-------
-2-
The alternatives discussed in the draft EIS include: no-action (with and
without future maintenance dredging); control of river flow; in-river
detoxification; dredging alternatives; remnant deposit alternatives in the
area of the former Fort Edward Dam; and full scale or reduced scale dredg-
ing program with in-river containment. These alternatives were evaluated
to determine both their feasibility and impact on the environment, includ-
ing primary and secondary impacts on public health, fisheries, maintenance
dredging and navigation, and agriculture.
The EIS is a decision making document. It is meant to bring together all
pertinent information on the issue at hand. Public participation, espe-
cially at the local level, is an essential component of the decision making
process.
Public participation meetings and meetings of the Citizens' Advisory Com-
mittee were held throughout the EIS preparation process with local, county,
state and federal representatives to discuss the issues. Three public
meetings were held to provide the general public an opportunity for input.
Three public hearings have also been scheduled for June 23, 24, and 25, 1981
at the following locations:
June 23, 1981: 7:00PM
Washington County Courthouse
Route 4 and Maple Road
Hudson Falls, New York
June 24, 1981: 7:OOPM
Dutchess County Community College
Pendell Road
Poughkeepsie, New York
June 25, 1981: 6:30PM
2 World Trade Center
Main Hearing Room - 44th floor
New York, New York
Your participation at these hearings is encouraged. In addition, you may
submit written comments directly to EPA. Your written comments should be
addressed to Chief, Environmental Impacts Branch, USEPA-Region II, 26
Federal Plaza, Room 400, New York, New York 10278. Comments must be
received on or before July 6, 1981.
If you need any additional information, please contact Ms. Robin Rohn,
Project Officer, New York/Virgin Islands Section, Environmental Impacts
Branch, at (212) 264-8677.
Sincerely yours,
Richard T. Dewling, Ph.D.
Acting Regional Administrator
-------
DRAFT
' ENVIRONMENTAL IMPACT STATEMENT
FOR THE
HUDSON RIVER PCB DEMONSTRATION RECLAMATION PROJECT
May 1981
Prepared by:
U.S. Environmental Protection Agency - Region II
Cooperating Agencies:
U.S. Army Corps of Engineers New York State Department of
Environmental Conservation
Abstract; This environmental impact statement (EIS) has evaluated the
proposed Hudson River PCB Reclamation Demonstration Project from the
standpoint of public health, environmental impact, cost, and engineering
feasibility. As a result of these analyses, U.S. Environmental Protection
Agency (USEPA) recommends that the action alternative be implemented. The
full scale action alternative estimated at approximately $43 million dollars
has been determined to be the most desirable project in terms of potential
beneficial impacts., However, since the full scale project may not be
realized unless additional funds are obtained by New York State Department
of Environmental Conservation (NYSDEC), the reduced scale project is also
recommended.
As a part of the action alternative the development of a monitoring program
is recommended to demonstrate any improvement in the rate of recovery of
the Hudson River and the feasibility of the indefinite storage of PCB con-
taminated sediments in an upland containment site.
EPA has determined that this action, with the mitigation measures described
in the EIS, will not endanger public health, safety, and welfare.
The alternatives discussed in this draft EIS for the proposed Hudson River
PCB Reclamation Demonstration project include: the no-action alternative
(with and without future maintenance dredging); control of river flow;
in-river detoxification; dredging alternatives; remnant deposit alternatives
in the area of the former Fort Edward Dam; and full scale or reduced scale
dredging program with in-river containment. These alternatives are evalu-
ated to determine both their feasibility and impact on the environment.
This National Environmental Policy Act (NEPA) draft EIS is based largely on
the NYSDEC's State Environmental Quality Review Act draft EIS and supporting
documents. Significant impacts which were further evaluated in this NEPA
draft EIS include primary and secondary impacts on public health, fisheries,
maintenance dredging and navigation, and agriculture.
-------
-2-
Public Hearings;
June 23, 1981: 7:OOPM
Washington County Courthouse
Route 4 and Maple Road
Hudson Falls, New York
June 24, 1981: 7:OOPM
Dutchess County Community College
Dutchess Theater
Pendell Road
Poughkeepsie, New York
June 25, 1981: 6:30PM
2 World Trade Center
Main Hearing Room - 44th floor
New York, New York
Contact for Information;
Ms. Robin Rohn
U.S. Environmental Protection
Agency - Region II
Environmental Impacts Branch
26 Federal Plaza, Room 400
New York, New York 10278
(212) 264-8677
Approved by:
RicTiarfl T. Dewling/ Ph.D.
Acting Regional Administrator
Date?
-------
ENVIRONMENTAL IMPACT STATEMENT
ON THE HUDSON RIVER PCB
RECLAMATION DEMONSTRATION PROJECT
DRAFT
MAY, 1981
MASSACHUSETTS
Long Island Sound
Atlantic Ocean
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
NEW YORK, NEW YORK 10278
-------
EXECUTIVE SUMMARY
DATE: May 1981
TYPE OF STATEMENT: Draft
RESPONSIBLE FEDERAL AGENCY: U.S. Environmental Protection Agency (EPA)
Region II
TYPE OF ACTION: Administrative
RECOMMENDED ACTION
Based on public health, environmental, cost, and engineering evaluations
carried out by EPA and its environmental consultants, the EPA recommends that the
action alternative be implemented if contingency/mitigation measures ensuring
public safety are developed (Table S-l).
Resolution of these issues will ensure that minimal risk to public health,
safety, and welfare will result from the implementation of this project.
Modifications and contingencies developed will be submitted for public comment
before a National Environmental Policy Act (NEPA) decision is reached.
EPA recommends that a project to dredge and/or stabilize all known poly-
chlorinated biphenyl (PCB) hot spots be implemented. After carefully evaluating
both the original full-scale proposal and reduced-scale proposal submittted by
New York State Department of Environmental Conservation (NYSDEC), EPA recommends
funding a modification of the original full-scale project, since greater po-
tential benefits will be realized. However, if additional funding is not
available, the reduced-scale project is also recommended, although it offers
only a reduced potential benefit, because it will provide for demonstration of
river recovery and indefinite storage while not endangering public health,
safety, and welfare.
As discussed below, the authorization by Congress under Section 10 of the
Clean Water Act (CWA) Amendments is $20,000,000. If the action alternative is
S-l
-------
Table S-l
EPA Recommended Program
Full- Scale
Dredging or in-river containment of all
40 hot spot areas in the river bed with
containment in a secure upland site.
Design and construction of a secure
upland containment site capable of
indefinite long-term isolation of
contaminated material
Deletion of remnant deposit removal and
upland containment; instead, provision of
secure cap and top dress ing,and further
bank stabilization if necessary
Elimination of provision for the con-
tainment of PCB-contaminated material
from dumpsites in the Fort Edward area.
Provision for containment of contaminated
materials from three New York State
Department of Transportation (NYSDOT)
dredge spoil sites (212, 13 and 204 Annex)
Provision for dredging and containment
operational standards and procedures,
mitigation measures, monitoring programs,
and contingency plans necessary to safe-
guard public health and agricultural
resources
Provision for research studies/environ-
mental monitoring programs necessary
to demonstrate the improvement in the
rate of recovery of the river and
storage of contaminated material
Reduced-Scale
Reduction of the number of hot
spots to be dredged or contained
in-river
Same, except for a reduction in
capacity at the containment site
Same
Same
Same
Same
Same
S-2
-------
approved, the recommended action is to undertake the originally proposed $40,000,000
full-scale project with the required modifications. Additional funds from
either federal, state, or perhaps outside sources will be required to implement
the full-scale project, while affording protection of the public health and the
environment. Although not as desirable as the full-scale project, it is recom-
mended that the $26,700,000 reduced-scale project could be undertaken along with
the aforementioned project modifications.
HISTORY AND OVERVIEW OF THE EXISTING PROBLEM
Polychlorinated biphenyls are a class of chemical compounds that have
been used in agriculture and industry for decades. Since 1930, they have
been used principally in electrical transformers and capacitors, but they have
also been used in a variety of other products including lubricants, pesticides,
cutting oils, plasticizers, and adhesives.
During a thirty-year period ending in 1977, over 227,000 kilograms (kg)
(500,000 pounds [lb]) of PCBs were discharged into the Hudson River from two
General Electric (GE) capacitor manufacturing plants at Fort Edward and Hudson
Falls, New York. Much of the discharged PCBs was adsorbed by the bottom sedi-
ments of the river and accumulated behind the Fort Edward Dam. When the dam was
removed in 1973 due to its deteriorating condition, a large amount of the
PCB-contaminated sediments was released and migrated downstream. The downstream
migration was further accelerated during flood situations, causing PCBs to
concentrate in river bottom sediments from Fort Edward to New York Harbor.
PROJECT DEVELOPMENT BY NYSDEC
As part of a court settlement between NYSDEC and GE, approximately
$3,000,000 was spent by NYSDEC to investigate the extent of PCB contamination in
the Hudson River and methods to reduce and remove the threat of continued PCB
contamination.
Forty PCB "hot spots" have been identified in the upper Hudson River, based
on five years of scientific and engineering studies. Hot spots have been defined
as sediments containing 50 micrograms per gram (ug/g) (parts per million tppm] )
S-3
-------
or more of PCBs. PCB concentrations along the depositional shore range from 5
to 1,000 ug/g (ppm) in fine grained sediments. In addition, five PCB-contamin-
ated remnant deposits have been identified. Remnant deposits were formed by as
a result of the removal of the Fort Edward Dam, which caused water levels of the
river behind the dam to drop significantly. This caused once-submerged bottom
sediments to be exposed to the atmosphere. At present, PCB concentrations in
the remnant deposits range from 50 to 200 ug/g (ppm).
The investigations conducted by NYSDEC resulted in a project which proposed
to demonstrate the feasibility of removing PCB-contaminated sediments from the
upper Hudson River and deposit those sediments in a secure upland containment
site. The environmental analysis, costs, engineering, and feasibility of the
project proposed by NYSDEC are presented in a draft environmental impact state-
ment (EIS) prepared in accordance with the State Environmental Quality Review
Act (SEQRA). The full-scale project recommended in the draft SEQRA EIS was
estimated to cost $40,000,000.
Subsequent to the draft SEQRA EIS and in response to Congressional action
described below, NYSDEC rescoped the originally proposed project to accommo-
date the $20,000,000 funding authorized by the amendments to the Clean Water
Act (CWA) [Sections 116(a) and (b)] and State matching funds. The reduced-scale
project, as developed by NYSDEC, would cost $26,700,000. A comparison of the
full- and reduced-scale projects is presented in Table S-2.
CONGRESSIONAL ACTION
In September 1980, Congress passed an amendment to the CWA under Title I,
Section 116(a) and (b), entitled the Hudson River PCB Reclamation Demonstration
Project. Funds for this project have been authorized under Title II, Section
205(a) of the Act. Under this legislation EPA is authorized to expend up to
$20,000,000 towards a proposed demonstration/reclamation project for removing
and disposing of PCB-contaminated sediments from the Hudson River.
Section 116(a). The Administrator is authorized to enter into
contracts and other agreements with the State of New York to
carry out a project to demonstrate methods for the selective
S-4
-------
Table S-2
NYSDEC Recontmended Program
Full-Scale
Dredging of all 40 hot spot areas
in the river bed with containment in
a secure upland site
Design and construction of a secure
upland containment site capable of
long-term isolation of contaminated
material
Excavation of two remnant deposits
(areas 3 and 5) located above the
former Fort Edward Dam site, and
removal to the upland containment:
site
Provision for containment of material
from three PCB contaminated dump sites
(old Fort Edward, Fort Miller and
Caputo) should removal be found more
suitable than in-place containment
Provision for containment of con-
taminated materials from three
NYSDOT dredge spoil sites
(212, 13 and 204 Annex)
Destruction of the recovered PCBs
at such time as a technologically
and economically feasible procedure
becomes available
Provision for funding for research
studies related to environmental
monitoring
Reduced-Scale
Reduction of the number of hot
spots to be dredged from 40
to approximately 20
Same, except for a reduction in
in capacity at the containment
site
Deletion of remnant deposit
removal and upland containment;
instead provision of top
dressing and fencing for remnant
deposits 3 and 5
Elimination of provision for the
containment of PCB-contaminated
material from Old Fort Edward, Fort
Miller and Caputo dump sites.
Same
Same
Reduction in the level of funding
for research studies
S-5
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removal of polychlorinated biphenyls contaminating bottom
sediments of the Hudson River, treating such sediments as
required, burying such sediments in secure landfills and
installing monitoring system for such landfills. Such demons-
tration project shall be for the purpose of determining the
feasibility of indefinite storage in secure landfills of toxic
substances and of ascertaining the improvement of the rate of
recovery of a toxic contaminated national waterway. No pollu-
tants removed pusuant to this paragraph shall be placed in any
landfill unless the Administrator first determines that dis-
posal of the pollutants in such landfill would provide a higher
standard of protection of the public health, safety, and
welfare than disposal of such pollutants by any other method
including, but not limited to, incineration or a chemical
destruction process.
(b). The Administrator is authorized to make grants to the
State of New York to carry out this section from funds allotted
to such State under Section 205(a) of this Act, except that the
amount of any such grant shall be equal to 75 per centum of the
cost of the project and such grant shall be made on condition
that non-Federal sources provide the remainder of the cost of
such project. The authority of this section shall be available
until September 1983. Funds allotted to the State of New York
under Section 205(a) shall be available under this subsection
only to the extent that funds are not available, as determined
by the Administrator, to the State of New York for the work
authorized by this section under Section 115 or 311 of this Act
or a comprehensive hazardous substance response and cleanup
fund. Any funds used under the authority of this subsection
shall be deducted from any estimate of the needs of the State
of New York prepared under Section 516(b) of this Act. The
Administrator may not obligate or expend more than $20,000,000
to carry out this Section.
The overall goal of the Congressional authorization is to allocate funding
to assist in the cleanup of the PCBs in the upper Hudson River. The specific
purpose of the authorization is to demonstrate the improvement of the rate of
recovery of a toxic contaminated national waterway by:
selective removal of PCB-contaminated sediments from the Hudson River
treating the contaminated sediments as required and burying those sedi-
ments in a secure landfill
development of monitoring and scientific studies for water quality and
fish, and monitoring the landfill site
The legislation also states that prior to placing any contaminated materials
in a secure landfill the Administrator of EPA must first determine that the
S-6
-------
placement of the pollutants in a secure landfill would provide a higher degree of
protection of public health, safety, and welfare than either leaving the PCB-
contaminated sediments in place or disposition by any other methods. In addi-
tion, before funding under Section 116 of the CWA can be provided, the Admini-
strator of EPA must determine that funding is not available under Sections 115
and 311 of the Act, as well as any existing "Superfund" legislation (Compre-
hensive Hazardous Substance Response and Clean-Up Fund established by the
Act).
PURPOSE OF FEDERAL EIS
With the passing of the Section 10 Amendments to the CWA in October of 1980,
Congress authorized EPA to make grants to the NYSDEC in order to carry out
the intent of the "Hudson River PCB Reclamation Demonstration Project."
On January 12, 1981 EPA-Region II issued a Notice of Intent (NO!) to
prepare an EIS. The purpose of NEPA is to identify and analyze any potentially
significant impacts on the quality of the human environment resulting from a
proposed project.
In addition, the NEPA EIS decision-making process provided the forum for
soliciting public comments on the proposed project by conducting a series of
public meetings and hearings. A twenty-one member Citizens Advisory Committee
(CAC) has been formed to advise EPA on issues of public concern regarding the
project.
As stated in the NOI, it was EPA's intent to further evaluate the following
in the NEPA EIS:
no-action alternatives
control of river flow
in-river detoxification
in-river contamination
remnant deposit alternatives in the area of the former Fort Edward Dam
complete or partial dredging, combined with upland containment
dredge spoil disposal and treatment options
other alternatives concerning PCB removal, including alternative dredging
and transport
S-7
-------
These alternatives were evaluated for potential beneficial and adverse,
short- and long-term impacts under normal river flow, as well as flooding condi-
tions. The major primary and secondary impact assessment objectives are as
follows:
A. Public Health
1. Protection of downstream water supply
2. Protection of groundwater in the area of the containment site
3. Reduction of PCB volatilization from river bed/bank, and remnant
deposits into the air
4. Reduction of containment site volatilization
5. Reduction of exposure through the ingestion of food
B. Fisheries
1. Permanent reopening of the commercial and recreational fisheries
2. Protection of endangered species (shortnosed sturgeon)
3. Reducing the bioaccumulation of PCBs through the food web.
4. Protection of wetlands
C. Maintenance Dredging and Navigation
1. Mitigation of future maintenance dredging and disposal problems in
the upper Hudson River as well as the estuary
2. Maintenance of a navigable waterway serving transportation needs
of the upper and lower Hudson communities
D. Agriculture
Protection of livestock and their food sources through:
1. Reduction of river bed/bank, and remmant deposit volatilization
2. Reduction of containment site volatilization
3. Protection of groundwater in the area of the containment site used
for dairy industry purposes
E. Other Impacts
1. Evaluation of impacts to future hydroelectric dam construction
and usage
S-8
-------
FINDINGS OF THE NEPA EIS
1. Disposal of PCB-contaminated dredge spoils in a landfill would provide
a higher standard of protection of the public health, safety, and
welfare than disposal of such pollutants by other methods including,
but not limited to, incineration or a chemical destruction process.
The basis of the above conclusion is that alternative disposal methods
are either infeasible or highly speculative and would render the entire
project economically infeasible within the amounts of money available
for the "rescoped" project (i.e., $26.7 million).
2. The proposed containment site, incorporating the modifications and
safeguards described below, is environmentally sound for indefinite
storage of PCB-contaminated sediments. The storage of contaminated
sediments at the proposed containment site will not cause significant
long-term adverse environmental impacts to the surrounding communities.
3. The proposed dredging operation, incorporating the modifications and
safeguards described below, will not have significant short- or long-
term adverse effects on the surrounding community, downstream water
supplies or the ecology of the Hudson River.
4. Removal and in-river containment of substantial quantities of PCB-laden
sediments should demonstrate an improvement of the rate of recovery of
the Hudson River.
5. Removal and in-river containment of PCBs from the upper Hudson River
will also reduce the risk of:
contaminating downriver water supplies caused by high flow conditions
public health threats due to excessive volatilization from the river
bank areas
public health threats due to the consumption of contaminated fish
the necessity to close the Hudson River fishery due to high flows
after projected reopening
- . permanent closure of the striped bass fishery
- conducting environmentally unsound maintenance dredging and upland
disposal of contaminated sediment from the upper Hudson River and
estuary
closing navigable waterways both in the upper and lower Hudson River
due to the inability to provide adequate upland containment of
containment dredge spoil
- endangering aquatic species, in particular the shortnosed sturgeon
S-9
-------
6. Removal and in-river containment of PCBs from the upper Hudson River
is not expected to significantly reduce PCS sediment concentrations in
the New York Harbor.
7. As presently proposed by NYSDEC, PCB volatilization caused by the
discharge of contaminated dredged sediment into the containment site
could exceed the New York State Department of Health (NYSDOH) recom-
mended maximum allowable 24-hour average ambient air PCB concentration
at nearby residences and at other sensitive receptors under worst case
dissolved PCB concentrations and meteorological conditions. However, the
analysis conducted by EPA shows that with mitigation measures presented
below, the 1 microgram per cubic meter (ug/cu m) ambient air guideline
should not be exceeded.
MODIFICATIONS
The modifications to the original project, as well as to the reduced-scale
project referenced above, include changes in the design, operational standards,
contingencies, and long-term monitoring and maintenance. These recommendations
are consistent with the Congressional intent of Section 10 of the CWA Amendments.
The purpose of these modifications is to provide a higher standard of protection
for public health, safety, and welfare during dredging and disposal operations
and throughout the life of the containment site. Prior to the NEPA decision and
granting of federal funds to undertake site construction and dredging, the
modifications described below must be fully developed, submitted for public
comment, and approved by EPA.
Since neither the original or reduced-scale project contains the specific
provisions to carry out financial assurances, contingencies, long-term monitor-
ing, operational standards and procedures, operations and maintenance, or land
acquisition, the NYSDEC must obtain firm commitments for additional funding for
these provisions from either state or other federal sources prior to project
approval. Federal or state matching funds currently appropriated for this
project are not sufficient to be used for these purposes. These current funds
are to be used only for dredging, site construction and closure, and a monitor-
ing program for only the duration of the project operations. Although there are
a substantial number of modifications and additions to the original and reduced-
scale projects, most are directed toward long-term elements subsequent to con-
S-10
-------
tainment site closure, the costs of which are to be borne by New York State.
Therefore, the modified project should not substantially reduce the material
planned to be removed from the river.
The recommended modifications to the project are specified below under the
separate categories of "Dredging, In-River Containment, and Stabilization",
"Disposal", "Long-Term Storage", and "Water Quality Monitoring".
Dredging, In-River Containment, and Stabilization
1. Study and make recommendations to maximize in-river containment of hot
spots where feasible and cost effective. (This will be studied in
detail during the 45-day draft NEPA EIS review period).
2. Cap/in-place stabilization and denial of access of remnant deposits
3 and 5 as an immediate measure.
3. Maximize upriver flow regulation at Sagandaga Dam as a flood control
measure during the dredging operation.
4. Develop operational standards and procedures, mitigating measures,
monitoring programs, and contingency plans to eliminate excessive
volatilization and resuspension of PCB-contaminated sediments to
protect workers, residents, agricultural resources, and water supplies.
Disposal
1. Modify disposal operations at the containment site, including the
provision for smaller containment cells, addition of PCB adsorbents,
and possible cell cover during loading operations to minimize vola-
tilization.
2. Develop operational standards and procedures, contingency plans, and
monitor program surrounding the proposed containment site for the
duration of the disposal operations to assure the NYSDOH 1 ug/cu m
ambient air guideline is met, as well as the 0.2 ug/g (ppm) standard for
crops set by the U.S. Food and Drug Administration.
3. Develop specific contingency plans for additional treatment of the
supernatant from dewatering prior to discharge if permit limits (to be
established) are exceeded.
Long-Term Storage
1. Development of long-term maintenance and monitoring programs for a
minimum of 30 years with periodic program review by EPA and NYSDOH.
S-ll
-------
2. Contingency plans for (a) long-term leachate collection and treatment,
(b) landfill cap maintenance, (c) excessive PCB volatilization or
methane generation, and (d) alternate water supply should monitoring
indicate failure of containment site.
3. The development of grievance and arbitration procedures and the investi-
gation of the feasibility of liability insurance for any claims arising
in connection with the public health aspects of the project.
4. Provision for specific funding mechanisms by NYSDEC to assure imple-
mentation of long-term contingency plans, operation, maintenance, and
monitoring.
5. Redesign of the containment site leachate collection and storage system
to improve operations and to avoid clogging and buildup of leachate
within the site.
6. Provision for storage of NYSDOT maintenance dredging materials from
sites 212, 13, 204 Annex from Washington County only (if removal is
deemed necessary), under the condition that the state bear the incre-
mental costs associated with disposal and long-term storage.
Water Quality Monitoring
1. Develop a long-term monitoring program to evaluate the improvement of
the recovery rate of the river and fisheries.
2. Develop a long-term monitoring and maintenance program if in-river
containment is implemented to determine leaching of PCBs back into
the river.
3. Develop a downstream public water supply monitoring program for
PCBs and heavy metals to be implemented before, during, and after
dredging operations, especially during and shortly after high flows.
Contingency plans to provide additional water treatment or alternate
water supplies also should be developed.
4. Develop a short-term monitoring program for air quality, water quality,
and biota during dredging and disposal operations.
CITIZEN INVOLVEMENT
It is also recommended that if either the full-scale or the reduced-scale
project is undertaken, the CAC and the Settlement Advisory Committee (SAC) be
continued at least through the operational phase of the project, and beyond
S-12
-------
if so desired by the respective committees. The committees would serve as a
community focal point.for the distribution of project information and data and,
at the same time, provide oversight and local and technical liaison between the
affected communities and the operational and regulatory agencies, including EPA.
The CAC has raised two issues of public concern which should be considered
by New York State.
1. NYSDOT should develop a comprehensive PCB dredge spoil disposal
plan for the upper Hudson River, also within the same time frame
as this proposed proje:ct.
2. NYSDEC should consider providing assurances that neither the pro-
posed containment site nor the surrounding land acquired by New
York State will be used for the future disposal of any hazardous
waste generated from either within or outside Washington County.
S-13
-------
TABLE OF CONTENTS
Chapter Title
EXECUTIVE SUMMARY
TABLE OF CONTENTS i
LIST OF FIGURES v
LIST OF TABLES .AND PLATES vi
1 INTRODUCTION 1-1
History of the PCB Problem in the Hudson River... 1-1
Purpose of and Need for the Project 1-5
Drinking Water 1-6
Food . 1-6
Air 1-7
Heath Effects 1-8
Routine Maintenance Dredging 1-9
Hudson River Fishery 1-9
Congressional Action 1-10
Actions Proposed by the NYSDEC 1-11
Dredging 1-14
Remnant Excavation 1-14
Containment Site 1-15
Mitigating Measures . 1-15
Rescoping of the Recommended Alternative 1-15
Action by EPA , 1-18
Permits 1-18
State 1-18
Federal 1-19
PCB Standards and Recommendations 1-19
2 ALTERNATIVES CONSIDERED 2-1
MAJOR ALTERNATIVES
The No-Action Alternative 2-1
No-Action (Assuming That Routine Channel
Maintenance Dredging Will Continue) 2-1
No-Action (Assuming That Routine Channel
Maintenance Dredging Will Be Halted) 2-5
Control of River Flows 2-6
In-River Detoxification 2-11
Degradation by Ultraviolet Ozonation 2-11
Chemical Treatment 2-11
Bioharvesting 2-11
Activated Carbon Adsorption 2-12
-------
TABLE OF CONTENTS
Chapter . Title
Dredging Alternatives - The Full-Scale Project 2-12
Dredging Alternative - The Reduced-Scale Project.. 2-13
Bank-To-Bank Dredging Project 2-16
ALTERNATIVE COMPONENTS
In-River Containment 2-16
Remnant Deposit Alternatives 2-18
No-Action 2-24
Denial of Access 2-24
In-Place Containment 2-25
Complete or Partial Removal 2-25
Transportation Alternatives 2-28
In-River Dredging Mechanisms 2-28
Clamshell Dredging/Mechanical Unloading . 2-31
Clamshell Dredging/Hydraulic Pumpout Unloading. 2-31
Hydraulic Dredging and Transport 2-34
Other Dredging Systems 2-35
Dredge Spoil Disposal 2-37
Detoxification 2-38
Containment in Upland Disposal Site 2-40
SELECTION OF THE RECOMMENDED ACTION
Recommended Action 2-44
Findings. 2-46
Modifications 2-47
Citizen Involvement 2-49
AFFECTED ENVIRONMENT (EXISTING CONDITIONS) . 3-1
Earth Resources 3-1
Regional Geological Setting 3-1
Containment Site Geology 3-4
River Bed Materials in Upper Hudson River 3-8
River Bed Materials in Lower Hudson River 3-12
Water Resources 3-12
Surface Water ; . . 3-12
Groundwater 3-14
Water Supply 3-16
Aquatic Ecology 3-17
Flora 3-18
Wetlands and PCB Hot Spots 3-19
Fauna 3-23
Hudson River Fishery 3-24
Terrestrial Ecosystem 3-32
Flora 3-32
PCB Levels in Terrestrial Flora 3-33
Fauna 3-37
Agriculture 3-37
Threatened or Endangered Species 3-38
11
-------
TABLE OF CONTENTS
Chanter Title
Environmentally Sensitive Area 3-40
Cultural Resources 3-40
Scenic and Recreational Areas 3-43
Floodplains and Wetlands ' 3-43
Air Resources 3-44
Climate 3-44
Air Quality 3-45
ENVIRONMENTAL CONSEQUENCES OF FEASIBLE ALTERNATIVES 4-1
MAJOR ALTERNATIVES
The No-Action Alternative 4-2
No-Action (Assuming That Routine Channel
Maintenance Dredging Will Continue) 4-2
No-Act ion(Assuming That Routine Channel
Maintenance Dredging Will be Halted) 4-10
Control of River Flows 4-11
In-River Detoxification 4-11
Full-Scale Project 4-11
Reduced-Scale Project 4-16
Bank-To-Bank Dredging 4-18
ALTERNATIVE COMPONENTS
In-River Containment 4-18
Remnant Deposit Alternatives 4-23
No-Act ion 4-23
Denial of Access 4-28
In-Place Containment 4-31
Complete and Partial Removal 4-36
In-River Dredging Mechanisms 4-41
Containment Site. . 4-58
FEDERAL, STATE, LOCAL AND OTHER SOURCES FROM WHICH
COMMENTS HAVE BEEN REQUESTED 5-1
ABBREVIATIONS USED 6-1
CORRESPONDING ENGLISH AND METRIC UNITS 7-1
REFERENCES 8-1
LIST OF PREPARERS 9-1
APPENDICES
Appendix A - Health Exposure and Risk Assessment A-l
for Residents in the Vicinity of
Operations Associated with the
Dredging of the Upper Hudson River
111
-------
TABLE OF CONTENTS
Chapter Title
Appendix B - PCB Hot Spot Dredging Program
Upper Hudson River, New York,
Rescoping Report B-l
Appendix C - Review of the Sediment Transport
Model and the PCB Ecosystem Model C-l
Appendix D - Cost Estimates for In-River Containment
of Hot Spots and Covering of Rem-
nant Deposits D-l
Appendix E - Water Quality Data E-l
Appendix F - Hudson River Fish Fauna F-l
Appendix G - Hudson river Fish PCB Analysis 1979
and 1980 Samples G-l
Appendix H - Air Quality Data H-l
Appendix I - Recommended Guideline for PCB Levels
in Air 1-1
Appendix J - Estimate of Maximum Probable PCB
Flux to the Atmosphere from the
Hudson River Sediment Disposal
Basin J-l
SUPPORTING DOCUMENTS (Available for inspection at designated depositories).
Boyce Thompson Institute for Plant Research, Inc. 1977. An atlas of the
biologic resources of the Hudson Estuary. Boyce Thompson Institute for
Plant Research, Inc. Yonkers, New York.
Malcolm Pirnie, Inc. 1980. PCB hot spot dredging program, upper Hudson
River, New York. Draft environmental impact statement. Prepared for
New York State Department of Environmental Conservation, Albany, New
York.
New York State Department of Environmental Conservation and United States
Fish and Wildlife Service. 1978. Hudson River fish and wildlife report.
Hudson River level B study. 27 pp. + appendices.
IV
-------
LIST OF FIGURES AND PLATES
Figure
Number
1-1
2-1
2-2
2-3
2-4
3-1
3-2
4-1
Plate
Number
1
2
3
4
Title
Generalized Location
River Flows and Concentrations
In-River Containment Alternatives
Dredge Illustrations
Alternative Dredging Systems
Rainfall - Intensity - Duration -
Frequency Curve for Albany, New York
PCB Concentrations in Ambient Air at
Washington County Offices
Areas Used for Containment Site Modeling
Title
Location Map - 1 (River Mile 154 to 174)
Location Map - 2 (River Mile 174 to 197)
Original Containment Site
Rescoped Containment Site
Following
Page
1-2
2-10
2-18
2-32
2-32
3-44
3-52
4-66
-------
LIST OF TABLES
Number Title , Page
1-1 Major Events in the Hudson River that Pertain to 1-3
the PCB Problem
1-2 Methods of Managing PCB-Contaminated Sediments in 1-12
the Hudson River
1-3 Estimated Program Costs 1-16
1-4 PCB Standards and Recommendations 1-20
2-1 Major Alternatives and Alternative Components 2-2
2-2 PCB Transport: No-Action Alternative (with Navigational 2-4
Dredging and Volatilization)
2-3 PCB Transport: No Routine Maintenance Dredging 2-7
(with volatilization)
2-4 Comparison of Flow Contributions 2-9
2-5 Average PCBs in the River Water Column 2-10
Between Schuylerville and Stillwater
2-6 PCB Transport: Full-Scale Alternative 2-14
2-7 PCB Transport: Reduced-Scale Alternative v 2-15
,^
2-8a Estimated Mass of PCB in Remnant Deposits 2-20
(metric measure)
2-8b Estimated Mass of PCB in Remnant Deposits 2-21
(English measure)
2-9a Remnant Deposit Alternatives (metric measure) 2-29
2-9b Remnant Deposit Alternatives (English measure) 2-30
2-10 PCB Losses: Clamshell Dredging/Hydraulic Pumpout 2-33
Unloading
2-11 PCB Losses: Hydraulic Dreding and Transport 2-36
2-12 EPA Recommended Program 2-45
3-1 Characteristics of Soils Within the Containment 3-7
Site
3-2 Bed Deposit Properties 3-10
VI
-------
LIST OF TABLES
Number Title Page
3-3 Hot Spots and Wetlands 3-20
3-4 Means and Ranges of PCB Levels in Hudson River Fish 3-28
3-5 PCB Trends for Striped Bass, Hudson River, 1973-80, 3-30
Tappan Zee Bridge
3-6 Increases in Foliage PCB Levels 3-35
3-7 Foliage PCB Levels Near Fort Miller Dumpsite 3-36
3-8 Summary of Cultural Resources Identified at Site 10 3-42
3-9 Total Suspended Particulates from High Volume Air 3-46
Samples at Selected Stations, Upper Hudson River,
1979
3-10 Settleable Particulates from 30-Day Dustfall Jars 3-47
3-11 PCB Air Sampling by the New York State Department 3-48
of Health
3-12 Ambient PCB Levels at Site 10 and Lock 6 Dam 3-52
3-13 Summary Tabulation of Air PCB Data by NYDEC 3-53
Division of Air Resources
4-1 Estimates of Total Daily PCB Ingestion 4-5
VI1
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CHAPTER 1
Introduction
-------
CHAPTER 1
INTRODUCTION
1. HISTORY OF THE PCS PROBLEM IN THE HUDSON RIVER
The Hudson River is one of the most heavily PCB-contaminated bodies of
water in the United States. The greatest mass of contaminated sediments are
located in the upper Hudson River above Troy, New York. However, as a result
of sediment migration, the effects of PCBs have now been identified farther down-
stream. As a result, the affected area now encompasses the Hudson River region
from Glens Falls to the New York Bight. A map indicating the geographic location
of the project study area is presented in Figure 1-1.
Polychlorinated biphenyls (PCBs) are a class of chemical compounds that
have been used in agriculture and industry for decades. Since 1930, PCBs have
been principally used in electrical transformers and capacitors but they also
have been used in a variety of other products, including lubricants, pesticides,
cutting oils, plasticizers, and adhesives.
Malcolm Pirnie, Inc. (MPI, 1980d), reports that during a 30-year period
ending in 1977, over 22,700 kilograms (kg) (500,000 pounds [lb]) of PCBs were
discharged to the upper Hudson River in the waste stream of two General Electric
(GE) capacitor manufacturing plants at Fort Edward and Hudson Falls and from
other relatively minor sources. Much of the contaminated material that had
accumulated behind the former Fort Edward Dam was released downstream when the
dam was removed in 1973 and during subsequent floods. Belatedly, PCBs were
recognized as toxic, persistent pollutants. Though ubiquitous in their dis-
tribution, they were found in higher concentrations and mass in the Hudson River
than were previously known to exist in any other North American body of water
(MPI, 1980d).
1-1
-------
Theoretically, there are 210 types (homologs) of PCBs. PCBs were avail-
able commercially as mixtures (aroclors) of 20 to 75 homolgs and marketed by
the weight of chlorine contained in the mixtures. (MPI, 1980d). The compo-
sition of the PCBs discharged into the upper Hudson River by GE is reflected
by purchase records of the two GE plants (Bopp and others, 1981). Between
1966 and 1970 more than 98 percent of their PCB purchases consisted of Aroclor
1242. In 1971, Aroclor 1242 was replaced with Aroclor 1016, a very similar
aroclor. Between 1972 and 1976 more than 99 percent of the purchases were
Aroclor 1016. Cumulative purchases between 1966 and 1975 were 68 percent Aroclor
1242 and 31 percent Aroclor 1016 small quantities of Aroclor 1254 were used in
the GE plants prior to 1966. A reasonable estimate for the entire period of
plant operations is that 1242 comprised 80 percent of total purchases with the
remainder principally 1016 and 1254 (Bopp and others, 1981). All three aroclors
are now found in the sediments, water column, and biota of the Hudson River (MPI,
1980d).
In a suit brought by New York State Department of Environmental Conser-
vation (NYSDEC) in 1976, GE was found to be largely responsible for the high
concentrations of PCBs found in the Hudson River water, sediments, and organ-
isms. As a result, GE was required to reduce its daily discharges of PCBs to
454 grams (g) (1 Ib) and to build wastewater treatment facilities at their
Hudson Falls and Fort Edward plants. By 1977, daily PCB discharges from the
GE plants had been reduced to less than 1 g (0.022 Ib) (NYSDEC, 1977a). A
brief outline of the history of the PCB problem is listed in Table 1-1.
Much of the PCB-contaminated material that washed downstream after the
removal of the Fort Edward Dam concentrated in riverbed sediments from Fort
Edward to the Federal Dam at Troy. In some cases, the concentration of PCBs
in these sediments exceeds 50 micrograms per gram (ug/g) (50 parts per million
[ppm]). These highly contaminated sites have been labeled hot spots. As a
result of a survey completed during the summer of 1976, 40 hot spots have been
identified in the upper Hudson River. An additional five areas of PCB deposition
were exposed to the air when water levels dropped after the Fort Edward dam
1-2
-------
25
Scale in Kilometers
15 0 15
fc=
Scale in Miles
FIGURE 1-1
GENERALIZED LOCATION
25
50
30
ATLANTIC OCEAN
-------
Table 1-1
Major Events in the Hudson River that Pertain to the PCS Problem
Date
Event
1822
1898
1950-1970
1950-1976
1973 (July-October)
1973-1974 (July-July)
1973 (Spring)
1974-1975
1974-1975 (October-July)
1976 (April 2)
1976 (September)
1976
1977 (July)
1977 (September-December)
1978 (April-June)
Fort Edward Dam completed
Fort Edward Dam reconstructed
Navigational dredging removes an average 17,600
cu m (23,000 cu yd) per year in Fort Edward area
General Electric discharges some 22,700 kg
(500,000 Ib) PCBs to Hudson River from two
capacitor plants in Hudson Falls and Fort Edward
Fort Edward Dam removed because its condition is
deteriorating
650,000 cum (850,000 cu yd) are scoured from
former dam pool and 604,000 cu m (790,000 cu yd)
deposited in east and west channels near Rogers
Island
22,900 cu m (30,000 cu yd) dredged by contractor
to Scott Paper Company
470,200 cu m (615,000 cu yd) dredged by NYSDOT
from east and west channels near Rogers Island
Timber rock cribs removed; rock placed to staba-
lize remnant deposits 3 and 4; banks shaped;
dumped rock stabilizes remnant deposit 5
100-year flood occurs; additional 198,800 cu m
(26,800 cu yd) scoured from unstabilized areas
in former dam pool
General Electric reduces daily PCB discharges to
454 g (lib) PCBs into Hudson River from the
capacitor plants in Hudson Falls and Fort Edward
26,800 cu m (35,000 cu yd) dredged in the vicini-
ty of of buoy 212 by NYSDOT; fishery closed
General Electric reduces daily PCB discharges to
less than 1 g (0.022 Ib) PCBs into Hudson River
from two capacitor plants in Hudson Falls and
Fort Edward
37,600 cu m (180,000 cu yd) dredged from east
channel and placed in new Moreau site
1-3
-------
Table 1-1 (continued)
Date Event
1978 (June-August) Banks of remnant deposits 3 and 5 restabilized
1978 (October) 10,750 cu m (14,000 cu yd) excavated from remnant
deposit 3a and moved to Moreau site
Note: Place names referred to in this table may be located on Plates 1 and 2
of this report.
Source: MPI, 1980d
1-4
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was removed. A portion of one of these five remnant areas was removed by NYSDEC
in October 1978, and deposited in the new Moreau landfill. At present five
remnant areas remain in the Fort Edward area and may be contributing to PCB
contamination of the Hudson River and the ambient air. The locations of the
identified hot spots and remnant areas are shown on Plates 1 and 2.
In addition to the hot spots and remnant areas, several landfills and New
York State Department of Transportation (NYSDOT) dredge disposal sites in the
area are known to contain PCBs and may contribute to PCB levels in the Hudson
River and the air. Other as yet unidentified sources of PCB contamination may
also exist.
2. PURPOSE OF AND NEED FOR THE PROJECT
PCBs have several characteristics that make them toxic to animals,includ-
ing human beings. They collect (bioaccumulate) .and concentrate (biomagnify)
in the fatty tissue of all organisms (e.g., the amount of PCBs in a fish can
be many times greater than the amount in the surrounding water). Because
they are chemically stable compounds, they persist in the environment for
many years. They have been shown experimentally to have a wide range of toxic
effects. In addition to the health effects associated with PCBs, toxic impurit-
ies such as polychlorinated dibenzofurans (PCDFs) and chlorinated napthalenes
are often closely associated with PCBs (MPI, 1980d). The presence of these
impurities amplifies the PCB problem (Appendix A).
The presence of PCBs, as well as heavy metals in the sediments of the upper
Hudson River, poses a potential health risk to humans and other organisms from
three principal sources:
drinking contaminated water
eating contaminated food
breathing contaminated air
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2a. Drinking Water
Several communities obtain their drinking water from the Hudson River.
These communities include the Village of Waterford, Port Ewen Water District,
the Village of Rhinebeck, the City of Poughkeepsie, and the Highland Water
District. In addition, several municipalities, such as Stillwater and Green
Island, draw water from infiltration galleries located along the upper Hudson
River. Many households draw water from wells located close to the Hudson
River.
The U.S. Geological Survey (USGS) maintains five gaging stations in the
upper Hudson River at Glens Falls, Rogers Island, Schuylerville, Stillwater, and
Waterford (MPI, 1980d). At the Glens Falls gaging station, located above the GE
plants, concentrations of PCBs are usually below the detectable level of 0.1
micrograms per liter (ug/1) (0.1 parts per billion [ppb]) (Tofflemire, NYSDEC,
1980). From 1976 to 1979 the average concentrations at Schuylerville and Still-
water ranged from 0.568 ug/1 (ppb) to 0.687 ug/1 (ppb) (Tofflemire, 1980).
However, where suitable treatment facilities are available, PCBs can be removed
from river water, leaving it suitable for drinking. As shown by tests conducted
in 1972 by the City of Poughkeepsie, PCB levels in Hudson River water can be
reduced by 40 to 80 percent through activated carbon filtration (Cranston,
1977). This removal rate resulted in PCB concentrations in the treated water
below the maximum level of 1.0 ug/1 (ppb) presently recommended by the New York
State Department of Health (NYSDOH). At present there are no PCB standards in
either the federal or state drinking water regulations.
2b. Food
As mentioned previously, a characteristic of PCBs that makes them dangerous
to humans and other animals is that they collect and concentrate in the fatty
tissues and the fatty portions of blood and milk. This characteristic causes
PCBs to appear in relatively high concentrations in meat, fish, and poultry
products.
Comprehensive human food monitoring data on PCB levels are not available
for the Hudson River area. However, the U.S. Food and Drug Administration (FDA)
1-6
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conducts an annual comprehensive food surveillance program to determine the
concentrations of pesticide residues, PCBs, heavy metals, and other contaminants
in the diets of U.S. "consumers. Data for the period from 1969 to 1977 indicate
that during this period the total daily intake of PCBs per person dropped from
15.0 to 8.7 micrograms per day (ug/d). However, intake of PCBs from the meat-
fish-poultry categorize changed little (9.5 to 8.1 ug/d). The decrease of PCBs
in total diet is attributable to decreasing levels of PCBs in food packaging
material after 1974 (USEPA, 1976b).
The present FDA standards for PCB in food are:
Milk fat and dairy products 1.5 ug/g (ppm)
Poultry 3.0 ug/g (ppm)
Eggs 0.3 ug/g (ppm)
Fish and shellfish 5.0 ug/g (ppm)
Finished animal feed (including hay) 0.2 ug/g (ppm)
Since the FDA data indicate that the meat-fish-poultry category is primar-
ily responsible for dietary intake of PCBs, the possible local exposure to PCBs
resulting from the opening of the fishery in the upper Hudson River must be
considered. The FDA data on PCB concentrations in fish ranged from trace
levels to 0.05 ug/1 (ppm); the data on PCB levels in fish from the the upper
Hudson River indicate levels ranging up to 500 ug/1 (ppm) (Thomann and St.
John, 1979). Some illegal commercial fishing and some subsistence fishing are
believed to take place in the upper Hudson River despite the NYSDEC ban.
Populations along the Hudson River that do not consume fish taken directly
from the river are expected to be exposed to at least 9 ug/d of PCBs through
injestion of food. This figure represents the national background level es-
timated by EPA. Consumption of Hudson River fish with PCB levels at the 5 ug/g
(ppm) FDA standard could increase this amount by 100 times to approximately 900
ug/d (Appendix A).
2c. Air
PCBs volatilize, or escape into the air, from a variety of sources includ-
ing plastics, gas lines, and oils. For example, the average PCB concentration
in a kitchen has been reported at 0.32 micrograms per cubic meter (ug/cu m)
(USEPA, 1976b). The populace in Fort Edward and Hudson Falls is exposed to a
1-7
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general background concentration of 0.05 to 0.10 ug/cu m (Kerr, NYSDEC, May 8,
1980), and the rural populace is exposed to concentrations of less than 0.01
ug/cu m (Buckley, Boyce Thompson Institute for Plant Research, Inc. [BTI], April
9, 1981). These exposure levels are due to PCB volatilization from the river,
remnant deposits and disposal sites. Residents of the upper Hudson River are
therefore exposed to between 0.7 to 4.6 ug/d of PCBs, depending on the amount of
time an individual spends indoors (Appendix A). Residents adjacent to existing
dumpsites containing PCBs could be exposed to greater levels.
In 1977, the National Institute of Occupational Safety and Health (NIOSH)
proposed an 8-hour (hr) maximum allowable PCB exposure in air of 1 ug/cu m. The
existing Occupational Safety and Health Administration (OSHA) standard for 8-hour
maximum allowable PCB exposure in air is 500 ug/cu m. However, these standards
refer to industrial situations and are therefore not directly applicable to
outdoor ambient air conditions. In a letter dated March 25, 1981, NYSDOH recom-
mended that "...the 24 hour average PCB concentrations in the ambient air at
occupied residences and other sensitive receptors,..do not exceed 1 ug/cu m"
(Appendix I ) .
2d. Health Effects
PCBs have been associated with a variety of adverse health effects (World
Health Organization [WHO], 1976). Studies performed with rats, mice, and monkeys
revealed that various types of toxicity are associated with PCBs, including liver
damage, reproduction effects, skin disturbances, and cancer. Although most of
these data are available for species other than humans, humans appear to be
the species most sensitive to PCBs (WHO, 1976).
Considerable study has been given to an incident that occurred in 1968 in
Japan. Rice oil contaminated with PCBs was consumed by the general populace
(WHO, 1976). Health effects included chloracne, increased pigmentation of the
skin, increased eye discharge, visual disturbances, weakness, numbness, head-
aches, and liver dysfunction. Babies born to exposed mothers during this time
were smaller than average and had skin discoloration. By May of 1975 a total of
1-8
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1,291 related disease cases were reported. However, it was discovered than an
extremely toxic impurity, PCDF, was present in the contaminated oil and that this
may have been responsible for some or all of the toxic effects. Rhesus monkeys
exposed to pure PCBs at levels similar to those in the rice oil, however, de-
veloped similar symptoms (Allen and others, 1974).
Health effects specific to PCB exposure have been documented for industrial
workers involved in the direct manufacture or use of PCBs. These effects include
chloracne, fatigue, headaches, numbness of limbs, and swelling of joints
(Matthews and others, 1979). However, PCB effects on the general population
from environmental exposure have not been well documented (MPI, 1980d). Health
effects of exposure to PCBs are discussed in more detail in Appendix A.
2e. Routine Maintenance Dredging
The regulations pursuant to the Toxic Substances Control Act (TSCA) of
1976 require that special precautions for upland disposal be provided for those
substances, such as sediments and liquids, contaminated by greater than 50 ug/g
'(ppm) of PCBs. Based on required procedures for determining the disposal options
for the dredge spoils obtained through normal channel maintenance operations in
the lower Hudson River, the presence of concentrations of PCBs greater than 4
ug/g (ppm) could make ocean disposal infeasible in the future (Curll, Save Our
Ports, March 24, 1981). Therefore, the PCB-contaminated sediments in the Hudson
River, as discussed above, have the potential for imposing severe economic
hardships on upper and lower Hudson River communities that depend on dredging to
keep ports operating and channels navigable.
2f. Hudson River Fishery
The Hudson River fishery resource is of considerable local and regional
importance. It serves as a commercial and recreational fishery as well as a
major spawning area for fishes of the eastern Atlantic. Sheppard (1976) esti-
mated that the Hudson River could potentially produce an annual commercial
finfish catch of 600,000 to 900,000 kg (1,240,000 to 1,960,000 Ib), worth
$261,000 to $426,500 (in 1976 dollars).
1-9
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The recreational fishery in the upper Hudson River is presently closed
because of PCB contamination. In 1976, Sheppard estimated that the upper Hudson
River could potentially support 100,000 man-days of fishing (angler days), which,
at an average angler expenditure of $12.50 per day, would be worth $1,250,000
annually (in 1976 dollars). The recreational value of the lower Hudson River
fishery is currently on the order of $1,350,000 annually. Sheppard (1976)
estimates that the lower Hudson River may potentially provide over of a million
angler days of recreational fishing annually, worth over $12,500,000 (in 1976
dollars).
3. CONGRESSIONAL ACTION
In September 1980, Congress recognized the existing PCB problem in the
Hudson River by passing an amendment to the Clean Water Act (CWA) under Title I,
Section 116(a) and (b), entitled the "Hudson River PCB Reclamation Demonstration
Project". Funds for this project have been appropriated under Title II, Section
205(a) of the CWA. Under this legislation, the United States Environmental
Protection Agency (EPA) is authorized to expend up to $20,000,000 toward a
proposed demonstration reclamation project to remove and dispose of PCB-con-
taminated sediments from the Hudson River. The amendment reads as follows:
Sec. 116. (a) The Administrator is authorized to enter into
contracts and other agreements with the State of New York to carry
out a project to demonstrate methods for the selective removal of
polychlorinated biphenyls contaminating bottom sediments of the
Hudson River, treating such sediments as required, burying such
sediments in secure landfills and installing monitoring systems
for such landfills. Such demonstration project shall be for the
purpose of determining the feasibility of indefinite storage in
secure landfills of toxic substances and of ascertaining the im-
provement of the rate of recovery of a toxic contaminated national
waterway. No pollutants removed pursuant to this paragraph shall be
placed in any landfill unless the Administrator first determines that
disposal of the pollutants in such landfill would provide a higher
standard of protection of the public health, safety, and welfare than
disposal of such pollutants by any other method including, but not
limited to, incineration or a chemical destruction process.
(b) The Administrator is authorized to make grants to the State
of New York to carry out this section from funds allotted to such
State under Section 205(a) of this Act, except that the amount of any
such grant shall be made on condition that non-Federal sources provide
the remainder of the cost of such project. The authority of this
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section shall be available until September 30, 1983. Funds allotted to
the State of New York under Section 205(a) shall be available under
this subsection only to the extent that funds are not available, as
determined by the Administrator, to the State of New York for the work
authorized by this section under Section 115 or 311 of this Act or a
comprehensive hazardous substance response and clean up fund. Any
funds used under the authority of this subsection shall be deducted
from any estimate of the needs of the State of New York prepared
under Section 516(b) of this Act. The Administrator may not obligate
or expend more than $20,000,000 to carry out this Section.
4. ACTIONS PROPOSED BY THE NYSDEC
As a result of enforcement action taken by the NYSDEC against GE and a
subsequent settlement, NYSDEC spent approximately $3,000,000 to investigate
the PCB contamination problem in the Hudson River. These studies described
the extent of PCB contamination and proposed methods to reduce and remove the
threat of continued PCB contamination of the Hudson River. The culmination of
this effort was the issuance of a draft State Environmental Quality Review
Act (SEQRA) Environmental Impact Statement (EIS) prepared by MPI (1980d).
The alternative originally recommended by NYSDEC in the draft SEQRA EIS
(MPI, 1980d) included the following components:
dredging of 40 hot spot areas in the river bed with containment in a
secure upland site
design and construction of a secure upland containment site capable of
long-term isolation of contaminated material
excavation of remnant deposits 3 and 5, located above the former Fort
Edward Dam site, and removal to the upland containment site
provision for containment of material from three PCB-contaminated
dumpsites in the Fort Edward area should removal be found more suitable
than in-place containment
provision for containment of contaminated material from three NYSDOT
dredge spoil sites
destruction of the recovered PCBs at such time as a technically and
economically feasible procedure becomes available
In arriving at their recommended alternative, NYSDEC and its consultant,
MPI, first examined the feasibility of several alternative methods of managing
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Table 1-2
Methods of Managing PCB-Contamlnated Sediments
in the Hudson River
Alternatives
Status of
Technologic
Development
Potential Constraints or
Environmental Problems
In-Situ Control
Degradation by
ultraviolet
ozonation -
Chemical
treatment
Erosion control
of river bottom
Covering PCB-contam-
inated sediments
Developed for
closed system
applications
Conceptual
Conceptual
Conceptual
Treatment requires closed
reaction vessel
Possible ecological side
effects
Interference with
navigation
Massive disturbance of
ecosystem. Rupture of
seal or ballooning of
plastic due to gas for-
mation. Placement and
stabilization of cover
difficult
Removal
Bioharvesting
Activated carbon
adsorption
Dredging
Conceptual
Laboratory
Demonstrated on
small scale, Fort
Edward Channel
'The time and costs involved
with harvesting enough fish
are prohibitive. Tremendous
ecological side effects
Technology for application
and retrieval has not been
proposed
Untested on a large scale
1-12
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Table 1-2
(Continued)
Methods of Managing PCB-Contaminated Sediments
in the Hudson River
Alternatives
Status of
Technologic
Development
Potential Constraints or
Environmental Problems
On Land Control
Containment in
disposal site
Incineration
Chemical
detoxification
Biodegradation
Demonstrated at
new Moreau site
Demonstrated on
small scale
Laboratory
Laboratory
Lont-term monitoring
and maintenance
Large scale incinerator,
extensive use of fuel,
wet sediments
Best results with high
PCB concentrations
Aerobic reaction only,
with potential undesir- .
able byproducts
Source: MPI, 1980d
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PCB-contaminated sediments in the Hudson River, including the ultimately recom-
mended dredge and encapsulation alternative. These alternatives are summarized
in Table 1-2. Most of them, however, are somewhat conceptual in nature and
therefore would require several years of research and field demonstration before
they could be implemented. Hence, they failed to satisfy the dominant criterion
that led to the selection of the more feasible solution of hot spot dredging,
transport, and encapsulation: the need to remove PCBs as quickly as possible from
the river bottom in order to avoid downstream dispersal during flood flows.
Once NYSDEC concluded that dredging presented the most feasible means of hot
spot management, alternative dredging programs, various types of dredge equip-
ment, alternative remnant deposit excavation programs, candidate containment
sites, and various mitigation measures for maximizing long-term isolation of
PCB-contaminated material at the containment site were evaluated. The draft
SEQRA EIS and its supporting documents indicate that these components of the
recommended alternative would result in the containment of 40 to 50 percent of
the PCB estimated to be in the upper Hudson River. The following sections
briefly describe each of the components of the alternative recommended by the
NYSDEC.
4a. Dredging
The dredging operation would be preceded by an extensive sampling program
to specify further the exact locations and concentrations of PCB hot spots. A
combination of clamshell and hydraulic dredging, depending on distance from the
containment site, would then be used to remove the 40 hot spots from the river
bottom (Plates 1 and 2). Modifications to the equipment would be made to
limit the escape of contaminated dredge spoils back into the river. Again,
depending on the distance, the dredge spoil would either be pumped out hydraulic-
ally or be transported by barge to the containment site.
4b. Remnant Excavation
Two of the remnant deposits that have accumulated behind the former Fort
Edward Dam would be excavated and their material transported to the containment
site. It was decided to excavate portions of remnant areas 3 and 5, which
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contain the highest PCB levels, after evaluating various partial removal,
in-place encapsulation, and no-action alternatives for the remnant sites.
4c. Containment Site
A 100-hectare (ha) (250-acre [a]) containment site (Site 10), located 4
kilometers (km) (2.5 miles [mi]) south of the Village of Fort Edward, was
selected on the basis of size, clayey subsoil, accessibility, and environmental
and socioeconomic factors (Plate 3). A single site, rather than multiple sites,
was identified in order to realize economies of scale, to limit contaminated
material to a single location, and to reduce the amount of land needed for buffer
areas. The proposed site, which in addition to the containment area includes a
roughing and storage pond, surge pond, pump station, treatment plant, and le-
achate collection and stormwater drainage systems, would be fenced to restrict
public access, and a clay cover would be installed over the containment area to
reduce infiltration, erosion, and volatilization. The proposed cover consists of
a 46-centimeter (cm) (18-inch [in]) thick layer of clay overlain by gravel,
topsoil, and a shallow-rooted vegetative groundcover.
4d. Mitigating Measures
Various measures aimed at mitigating adverse environmental impacts at
each step of NYSDEC's recommended alternative are described in Chapter 9 of
the draft SEQRA EIS (MPI, 1980d). Of particular interest are the long-term
maintenance and moitoring activities proposed for the containment site and its
environs. Maintenance would include leachate collection, cap repairs, reseeding,
mowing, application of lime, and repair of drainage ditches. Monitoring includes
groundwater sampling, inspection of cap and cover crop, and sampling of cover
crop and adjacent vegetation for PCB contamination.
5. RESCOPING OF THE RECOMMENDED ALTERNATIVE
Cost estimates for the alternative originally recommended by NYSDEC cal-
culated for base year 1979 and escalated for inflation over a 3-year imple-
mentation period, are shown in Table 1-3. The estimated total cost of the
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Table 1-3
Estimated Program Costs
(Thousand Dollars)
Phase
Site Construction
Thompson Island
Pool Dredging
Remnant Pool
Deposits Removal
Lock 5 - Lock 6
Hot Spots Dredging
Locks 2, 3 & 4
Hot Spots Dredging
Sub-Total
Base
Year , .
1979 1980 1981 l '
$2259*^ $2711^ $2982
4847 6011 *3*
1698 2106^
2982 3698*3V
3359 4165*3*
$2982
Contingencies 796
Engineering Design 278
Field Engineering &
Construction Administration 384
Legal & Administrative 69
Totals By Year
Total For Project
$4509
Scientific, Engineering, Monitoring
& Administrative Costs 9/76-3/80
Scientific, Monitoring & Administrative
Estimated 4/80-3/83
1982^ 1983*4)
$7272
2548
$4922
504O
$9820 $9962
2664 2712
930 1018
1062 1493
257 293
$14733 $15478
$34,720
3,480
1,800
$40,000
Notes:
1. Includes site work costs for all phases
2. Escalated 20 percent
3. Escalated 24 percent
4. Escalated 10 percent/year
Source: MPI, 1980d
1-16
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project is $40,000,000. This amount is twice the level of federal funding
authorized by Congress in October 1980, under amendments to the CWA for the
Hudson River Reclamation Demonstration Project. As a result, the recommended
project was rescoped (scaled down) by NYSDEC to bring it within the total funding
available at the present time $20,000,000 of federal monies and $6,700,000 of
New York State monies.
The following criteria were used for the rescoping:
maximization of PCB removal from the Hudson River
program performance
cost-effectiveness
avoidance of wetlands
flexibility
Using these criteria, the NYSDEC proposed the following modifications
to the original project:
deletion of remnant deposit relocation and containment
provision of top dressing and fencing for remnant areas 3 and 5.
deletion of provision for NYSDOT spoil areas containment
elimination of provision for the containment of PCB-contaminated dumps
reduction of the number of hot spots to be dredged
reduction of capacity at the containment site
reduction in the scope of research studies
Reduction in the capacity of the containment site would result from reduc-
tions in the volume of material to be encapsulated, as well as a refined defini-
tion of materials handling requirements at the site. The reduced dredging
program is justified by NYSDEC on the basis that lower pool hot spots are more
expensive to recover, while containing less than one quarter of the PCBs (and at
a generally lower concentration) than PCBs found in the Thompson Island Pool.
Furthermore, lower pool hot spots, some of which are associated with wetlands,
are further from the proposed containment site and therefore more costly to
transport and encapsulate upland.
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6. ACTION BY EPA
With the passage of the Section 10 amendments to the CWA in October 1980,
Congress authorized EPA to make grants to the NYSDEC to carry out the intent of
the Hudson River PCB Reclamation Demonstration Project. The intent of the
legislation is discussed above (Section 3).
On January 12, 1981, EPA Region II issued a Notice of Intent (NOI) to
prepare an EIS in accordance with the National Environmental Policy Act (NEPA).
The purpose of NEPA is to identify and analyze significant impacts on the
quality of the human environment that may result from the federal funding of a
proposed action; in this case, the proposed dredging, disposal, and storage
activities associated with the Hudson River PCB problem.
In addition, the NEPA EIS decision-making process provided the forum for
soliciting public comment on the proposed project by conducting a series of
public meetings and hearings and by the formation of a Citizens Advisory Com-
mittee (CAC).
7. PERMITS
State and Federal permits which would be required for the dredge, fill, and
discharge operations are enumerated below. Additional information regarding
State and Federal permits is presented in Appendix B of the SEQRA EIS (MPI,
1980d).
7a. State
360 Permit
A complete application for a construction permit pursuant to the New York
State Solid Waste Management Facilities Rules must be submitted to NYSDEC for the
purpose of constructing a solid waste management facility.
Article 24
In accordance with recommendations of W.A. Huermann, Region 5W, Bureau of
Regulatory Affairs, a Freshwater Wetlands Permit will be required to construct
Site 10 and to dredge the river near hotspot No. 18 and hot spot No. 39.
364 Permit
If trucking is required for the removal and transport of contaminated
material from the remmnant deposits, the contractor must secure a permit pursuant
to the rules governing Collection and Transport of Industrial - Commercial and
Certain Other Wastes.
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State Pollution Discharge Elimination System
A SPDES permit will be required for the discharge from the containment site.
Streambed Disturbance Permit
This permit will not be required since the state is the applicant for this
project.
New York State Siting Board
A certificate of Environmental Safety and Public Necessity must be issued by
the Hazardous Waste Facilities Siting Board.
7b. Federal
Toxic Substance Control Act
A PCB disposal approval must be issued for this project by the EPA Regional
Adminstrator.
The Clean Water Act: Section 404
This permit will be required by the U.S. Army Corps of Engineers (USACOE) if
the discharge from the containment area is into navigable waters or adjacent
wetlands of the United States.
River and Harbor Act: Section 10
This permit will be required by the USACOE for dredging in navigable waters.
8. PCB STANDARDS AND RECOMMENDATIONS
The PCB standards and recommendations promulgated by state and federal agencies
are summarized in Table 1-4.
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Table 1-4
PCB STANDARDS AND RECOMMENDATIONS
Source of Intake
Maximum Allowable
PCBs
Food (FDA standards)
Milk fat and dairy products
Poultry
Eggs
Fish and shellfish
Finished animal feed (including hay)
Drinking Water (NYSDOH recommendation)
Ambient Air
Occupied residences and other sensitive
receptors (NYSDOH recommendation)
Worksite (OSHA standard)
Workside (NIOSH recommendation)
1.5 ug/g (ppm)
3.0 ug/g (ppm)
0.3 ug/g (ppm)
5.0 ug/g (ppm)
0.2 ug/g (ppm)
1.0 ug/1 (ppb)
1
1 ."0 ug/cu m
500 ug/cu m
1.0 ug/cu m
Note: 1. Proposed FDA revision to 2.0 ug/g (ppm)
2. 24-hour average; applicable to Hudson River reclamation project only
(Appendix I)
3. 24-hour average; if exceeded, respirators are required
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CHAPTER 2
Alternatives Considered
-------
CHAPTER 2
ALTERNATIVES CONSIDERED
This chapter presents a further evaluation and discussion of the alterna-
tives that NYSDEC offered in its draft SEQRA EIS, as well as additional alterna-
tives investigated by EPA in addressing the PCB problem in the Hudson River.
In some cases, a major alternative is comprised of a number of components.
Table 2-1 lists the major alternatives and components being examined. Each
major alternative and its respective components are discussed in the following
sections.
I. MAJOR ALTERNATIVES
1. THE NO-ACTION ALTERNATIVE
This EIS is being prepared in accordance with NEPA. Of great importance
in the NEPA EIS process is the evaluation of the no-action alternative. The
no-action alternative is typically an alternative not to fund any proposal
(as for example, the PCB dredging project proposed by NYSDEC) and includes a
consideration of what may happen in the project area if no action is taken. The
impacts of the no-action alternative in this case depend on two options: the
continuation of routine channel maintenance dredging or the cessation of it.
The effects of these options on the no-action alternative are discussed below.
1A. No-Action Alternative (Assuming That Routine Channel Maintenance Dredging
will Continue)
The no-action alternative includes no work beyond routine channel main-
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Table 2-1
Major Alternatives and Alternative Components
I. MAJOR ALTERNATIVES
1. THE NO-ACTION ALTERNATIVE
1A. Assuming that routine channel maintenance dredging will continue
IB. Assuming that routine channel maintenance dredging will be halted
2. CONTROL OF RIVER FLOWS
3. IN-RIVER DETOXIFICATION
3A. Degradation by ultraviolet ozonation
3B. Chemical treatment
3C. Bioharvesting
3D. Activated carbon adsorption
4. DREDGING ALTERNATIVESTHE FULL-SCALE PROJECT
5. DREDGING ALTERNATIVESTHE REDUCED-SCALE PROJECT
6. BANK-TO-BANK DREDGING PROJECT
II. ALTERNATIVE COMPONENTS
1. IN-RIVER CONTAINMENT (as an alternative to dredging))
2. REMNANT DEPOSIT ALTERNATIVES
2A. No-action
2B. Denial of access
2C. In-place containment
2D. Complete or partial removal
2E. Transportation alternatives
3. IN-RIVER DREDGING MECHANISMS
3A. Clamshell dredging/mechanical unloading
3B. Clamshell dredging/hydraulic pumpout unloading
3C. Hydraulic dredging and transport
3D. Other dredging systems
4. DREDGE SPOIL DISPOSAL
4A. Detoxification
physical destruction through incineration
chemical treatment
biodegradation
4B. Containment in upland disposal sites
dewatering by gravity
dewatering by mechanical methods
III. SELECTION OF THE RECOMMENDED ACTION
1. RECOMMENDED ACTION
2. FINDINGS
3. MODIFICATIONS
4. CITIZEN INVOLVEMENT
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estuary at Troy. It is important to note that, while the LMS model adequately
reflects the effects of short duration high flows on increasing PCB transport, it
does not take into account volatilization of PCBs nor routine maintenance dredg-
ing. PCBs are currently volatilizing from the upper Hudson River water at an
estimated rate of 1,350 kg/yr (3,000 Ib/yr) (Shen and Tofflemire, 1979). Adjust-
ing the LMS model for a 35-yr average annual volatilization rate of 680 kg/yr
(1,500 Ib/yr) of PCBs from the upper Hudson River and assuming a 35-yr average
routine dredging removal rate of 1,100 kg/yr (2,500 Ib/yr) of PCBs from the upper
Hudson River, the no-action alternative would result in the transport of 82,800
kg (182,000 Ib) of PCBs into the estuary over the next 33 years, where they would
be essentially unrecoverable (Table 2-2). During this period, 37,500 kg (82,500
Ib) of PCBs would have been removed from the upper Hudson River by routine
channel maintenance dredging, and 22,500 kg (49,500 Ib) of PCBs would have been
volatilized.
The estuarine portion of the river below the Federal Dam is estimated to
contain 75,700 kg (167,000 Ib) of PCBs (Bopp, 1979; Bopp and others, 1981). New
York Harbor is considered to have the greatest mass of PCBs below the dam,
totaling 23,100 kg (51,000 Ib) at an average concentration of 3 ug/g (ppm) (MPI,
1980d). This mass of PCBs in New York Harbor is 31 percent of the PCB load below
the Federal Dam. Bopp (1979) estimates that over the past 20 years, 1,800 kg/yr
(4,000 Ib/yr) of PCBs have been dredged from the harbor and that 70 to 75 percent
of the harbor's PCBs originated from discharges to the upper Hudson River.
Applying the results indicated in Table 2-2 and assuming that 1,800 kg/yr (4,000
Ib/yr) of PCBs are dredged from New York Harbor and that a maximum of 31 percent
of the PCB load at Troy enters New York Harbor, the average PCB concentration in
the harbor sediments would decline by approximately 2 ug/g by the year 2000. (If
it were assumed that 100 percent of the PCB load at Troy enters New York Harbor,
the average PCB concentration in the harbor sediments would double to approxi-
mately 6.0 ug/g (ppm) by the year 2013.) The average PCB concentration in Albany
turning basin sediments is higher than in New York Harbor sediments. Much of the
PCB load at Troy settles in the turning basin, causing the PCB concentrations to
continue to increase until the year 2013. The bioassay matrix presently used by
2-3
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Table 2-2
PCS Transport: No-Action Alternative
(with Navigational Dredging and Volatilization)
1
Period
Average Annual PCB
Load at Troy
kg/yr (Ib/yr)
Condition
1977 to 1978
1979 to 1994
1995 to 2013
After 2013
3,600 (8,000)
3,270 (7,200)'
1,950 (4,300)
0
(0)
Before remnant deposit actions
16 years to exhaust supply above Lock 7
19 years to exhaust supply between Lock 7
and Troy
Supply exhausted above Troy
1981 to 2013: 82,800 kg (182,000 Ib) of PCBs transported into estuary.
Notes: 1. Assumes volatilization rate of 680 kg/yr (1,500 Ib/yr) of PCBs
from upper Hudson River. This rate is the average volatilization
between 1981 and whatever year no PCBs remain in the upper Hudson
River, or 1/2 the current volatilization rate.
Assumes routine navigational channel maintenance dredging of 1,100
kg/yr (2,500 Ib/yr) of PCBs. This removal rate is the average rate
between 1981 and whatever year no PCBs remain in the upper Hudson
River, or 1/2 the current removal rate.
2. Loadings do not reflect yearly fluctuations of river discharges
and variations of the PCB mass transported.
3. Assumes contribution from remnant deposits is negligible.
2-4
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EPA and the USACOE for determining the viability of ocean disposal of PCB-con-
taminated sediments suggests that 4 ug/g (ppm) may be the highest acceptable PCB
level for ocean disposal (Curll, Save Our Ports, March 24, 1981). PCB hot
spots also contain high levels of certain heavy metals which would further
interfere with ocean disposal of dredge spoils.
Most PCB transport occurs during short duration high flows, not average
flows. (For quantitative analysis of high flows, see section 2 of this chapter.)
During very high upper Hudson River flows, substantial loadings of PCB will move
rapidly downstream. Although the LMS model (and the refinements of it presented
in Table 2-2) considers short duration high flows, it does not consider the
effects of uneven downstream deposition of PCB sediments. Deposition near a
potable water intake could thre:aten that supply. Deposition on a spawning ground
could threaten a species. Deposition in a navigational channel or docking area
could prevent disposal of dredge spoils in the ocean and require additional
upland containment sites for upper and lower Hudson River maintenance dredging
activities.
A problem that exists under any alternative until the fishery is reopened is
the health risk posed by illegal commercial fishing and subsistence fishing. The
no-action alternative would leave all the PCB sediments in the river, from which
fish will accumulate PCBs. When the commercial fishery is legally reopened,
PCDFs in cooked fish may continue to pose a substantial health risk. PCDFs,
which may be more concentrated in cooked fish than in raw fish, are 200 to 500
times more toxic than PCBs (FDA, 1979).
The no-action alternative described above does not require a containment
site. However, this does not preclude the possi^le_need_fo.r--containment sites in
the future to dispose of PCB contaminated sediments from maintenance dredging is
operations if dredging were to continue.
IB. No-Action Alternat i,ve--^('^ssuming That Routine Channel Maintenance
Dredging Will^be Halted)/
This alternative corresponds to the no-action alternative presented in
2-5
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the draft SEQRA EIS (MPI, 1980d) and in the Upper Hudson River PCB No-Action
Alternative Study (LMS, 1978). It assumes that routine channel maintenance
dredging in the upper Hudson River will be halted.
Adjusting the LMS model presented in the draft SEQRA EIS for a 50-yr
average annual volatilization rate of 680 kg/yr (1,500 Ib/yr) of PCBs from the
upper Hudson River, the no-action alternative would result in the transport of
112,000 kg (247,000 Ib) of PCBs into the estuary over the next 48 years, .where
they would be essentially unrecoverable (Table 2-3). During this period, 325,600
kg (72,000 Ib) of PCBs would be volatilized from the upper Hudson River. The
average PCB concentration in New York Harbor sediments would not increase, but
the levels in Albany turning basin sediments would continue to increase until the
year 2028.
This analysis indicates that if dredging were halted, 36 percent more PCBs
would be transported into the estuary than if dredging continued. In addition,
if dredging were halted, PCB transport would continue until the year 2028
rather than the year 2013. This alternative will have greater negative impacts
than the preceding no-action alternative. In addition to the adverse impacts
resulting from PCB-contaminated sediments remaining in the river, substantial
adverse impacts on the regional economy will result if routine maintenance
dredging is halted.
2. CONTROL OF RIVER FLOWS
Evaluation of the no-action alternative indicated that resuspension of
PCB-contaminated sediments and migration of PCB hot spots occur repeatedly
during high__river flows and that such movements of PCBs pose long-term risks to
(1) potable water supplies downstream, (2) the commercial fishery, (3) aquatic
and wetland biota, (4) the population of shortnose sturgeon, an endangered
species, and (5) future disposal of channel maintenance dredge spoils from the
estuary. This conclusion suggested an alternative that had not been considered
in the draft SEQRA EIS (MPI, 1980d) or in the rescoping report (Appendix B):
control of high river flows. The new alternative entails controlling, upper.
^~, _ -~_
Hudson River flows from one source, the Great Sagandaga Lake at the Conklingvil^le
2-6
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Table 2-3
PCB Transport: No Routine Maintenance Dredging
(with Volatilization)
Period
Average Annual PCB
Load at Troy
kg/yr (Ib/yr)
Condition
1977 to 1978
1979 to 1994
1995 to 2028
After 2028
3,600 (8,000)
3,270 (7,200)'
1,950 (4,300)
0
(0)
Before remnant deposit actions
16 years to exhaust supply above Lock 7
34 additional years to exhaust supply
between Lock 7 and Troy
Supply exhausted above Troy
1981 to 2028: 112,000 kg (247,000 Ib) of PCB transported into estuary,
Notes: 1. Assumes volatilization rate of 680 kg/yr (1,500 Ib/yr) of PCBs from
Upper Hudson River. This rate is the average volatilization between
1981 and whatever year no PCBs remain in the upper Hudson River, or 1/2
.the current volatilization rate.
2. Loadings do not reflect yearly fluctuations of river discharges and
variations of the PCB mass transported.
3. Assumes contribution from remnant deposits is negligible.
2-7
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Dam, where a substantial flow enters the upper Hudson River. However, the
major water source of the Hudson River enters from Lake Luzerne at Hadley.
Additional inflows from runoff, creeks, and groundwater enter the river between
the Sagandaga-Hudson confluence and Fort Edward. Table 2-4 compares the flow
contributions from these sources during average flows and during the 100-year
flood that occurred on April 2, 1976.
Since 1977, the USGS has operated PCB monitoring stations at Glens Falls,
Rogers Island, Schuylerville, Stillwater, and Waterford. Data from these moni-
tors indicate that PCB concentrations in the waters of the upper Hudson River are
flow-dependent. As shown in Figure 2-1, relatively high PCB concentrations occur
at low flows of less than 200 cubic meters per second (cu m/s) (7,000 cubic feet
per second [cfs]) between Schuylerville and Stillwater. The concentrations are
reduced in the moderate flow range and then increase again in the high flow
range, greater than 340 cu m/s (12,000 cfs) (MPI, 1980d). The average flow
between Schuylerville and Stillwater is 140 cu m/s (5,000 cfs); 10 percent of
the time the flow exceeds 340 cu m/s (12,000 cfs); and 1 percent of the time the
\j flow exceeds 765 cu m/s (27,000 cfs). However, if the data from Figure 2-1 are
I converted to load of PCBs in the river water column, rather than concentration,
I it becomes apparent that all flows less than 340 cu m/s (12,000 cfs) between
Schuylerville and Stillwater carry very low loads of PCBs (Table 2-5). Therefore
in order to avoid substantial resuspension and migration of PCBs it would be
necessary to prevent flows from exceeding approximately 340 cu m/s (12,000 cfs)
over the hot spots.
Based on the above analysis, it appears that the regulation of water flow
over the Conklingville Dam could not substantially contribute to achieving this
goal because flows greater than 340 cu m/s (12,000 cfs) occur 10 percent of the
time between Schuylerville and Stillwater (LMS, 1978). If the Board of the
Hudson River-Black River Regulating District were to develop an implementable
program that would reduce flows to less than 340 cu m/s (12,000 cfs), that
program would almost certainly conflict with its responsibilities to generate
hydroelectric power, to maintain navigable flows, and to protect the recreational
va,l.ue_of Great Sagandaga Lake. Therefore, this new alternative could only be
2-8
J
-------
Table 2-4
Comparisons of Flow Contributions
Location
of
Source
Lake Luzerne,
Hadley
Conklingville
. Dam
Other inflows
2
Fort Edward
a
_ Average Flows
Percent of
Flow at
cu m/s (cfs) Fort Edward
81 (2,850) 71.0
32 (1,130) 28.0
1 (20) 1.0
114 (4,000) 100
100-Year
cu m/s
883.6
229.4
20
1,133
Flood (April
(cfs)
(31,200)
(8.100)1
(700)
(40,000)
2, 1976)b
Percent of
Flow at
Fort Edward
78
20
2
100
Notes: 1. The maximum discharge from Conklingville Dam since its construction
in 1930 occurred on July 1, 1968, with a release of 377 cu m/s
(13,300 cfs') (USGS, 1975).
2. Ten percent of the time the flow exceeds 280 cu m/s (10,000 cfs).
One percent of the time the flow exceeds 590 cu m/s (21,000 cfs) (LMS,
1978).
Sources: a. USGS, 1975; LMS, 1978.
b. USGS, 1980.
2-9
-------
Table 2-5
Average PCBs in the River Water Column
between Schuylerville and Stillwater
Flow
cu m/s
28
57
142
198
283
340
425
566
708
849
(cfs)
(1,000)
(2,000)
(5,000)
(7,000)
(10,000)
(12,000)
(15,000)
(20,000)
(25,000)
(30,000)
PCB
ug/1
1.0
0.7
0.5
0.3
0.07
0.3
0.5
1.0
3.0
5.0
2
Concentration
(ppb)
(1)
(0.7)
(0.5)
(0.3)
(0.07)
(0.3)
(0.5)
(1.0)
(3.0)
(5.0)
PCB
kg/d
2.4
3.4
6.1
5.2
1.7
8.8
18.2
48.6
182.3
364.9
Load
(Ib/d)
(5.3)
(7.6)
(13.5)
(11.4)
(3.8)
(19.3)
(40.1)
(107.1)
(402.0)
(804.5)
Notes: 1. October 1977 through October 1979.
2. From Figure 2-1.
2-10
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Figure 2-1
River Flows and PCB Concentrations
.03
1.000
5.000
10.000
FLOW (cfs)
50,000 100,000
Note: Arrow (1) indicates percent (%) of time flow not exceeded
Source: MPI, 19804
-------
used as a short-term mitigating measure that would not eliminate the adverse
impacts of leaving the PCB hot spots in the upper Hudson River. In summary,
control of river flow is not a feasible long-term alternative.
f~~- - . . .---.""""'
3. IN-RIVER DETOXIFICATION
Alternatives discussed under this heading include:
degradation by ultraviolet ozonation
chemical treatment
bioharvesting
activated carbon adsorption
3A. Degradation by Ultraviolet Ozonation
Ultraviolet (UV) ozonation is commonly used for end-of-pipe treatment
for the water column. Although new uses for UV ozonation are being studied
(Valentine, 1981), they are still at the laboratory stage and are being developed
for end-of-pipe water treatment. This alternative does not seem feasible for
in-river treatment of sediments, but it should be assessed for treatment of
runoff from the proposed containment site.
3B. Chemical Treatment
In-river chemical treatment of PCB-contaminated sediments has received
little attention. The draft SEQRA EIS indicates that this alternative is
infeasible (MPI, 1980d).
3C. Bioharvesting
Both Horstman (1977) and MPI (1980d) conclude that bioharvesting is not a
feasible alternative. The technique involves harvesting all the aquatic organ-
isms in the Hudson River that have accumulated high PCB concentrations and
disposing of them in an environmentally acceptable manner. Estimates project
that this method would require anywhere from 100 to 10,000 years to complete.
2-11
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3D. Activated Carbon Adsorption
Activated carbon has an affinity for organic molecules and a large surface
to volume ratio that lends itself to effective removal of PCBs. Activated carbon
processes are widely used in treatment of industrial wastewaters and drinking
water. Most of these systems, however, consist of a column containing the acti-
vated carbon through which the wastewater is passed.
The alternative for removal of PCBs from the Hudson River involved a pro-
posal to utilize a granular magnetized activated carbon media that would be
applied to the bottom sediments as a slurry. The- retrieval would be accomplished
with a continuous belt-type collection device similar to those employed in
magnetic separators attached to a barge.
The cost for PCB removal utilizing this alternative was estimated to be in
the range of $122/ha to $l,215/ha ($300/a to $3000/a). This cost is very reason-
able when compared to other alternatives. However, this cost does not include
costs for storage or destruction of the contaminated carbon. In addition, this
_ _
alternative has never been tested in-river. Little is known about its effective-
ness or technological feasibility (Horstman, 1977).
4. DREDGING ALTERNATIVES THE FULL-SCALE PROJECT
The original project presented in the draft SEQRA EIS by NYSDEC included
/
six major components. VtDne component specified the dredging of all 40 hot spot
areas in the river bed and containment of the spoil in a secure, upland site.
The dredging was to take place over a two-year period. During the first year,
the 20 hot spots in the Thompson Island Pool were to be dredged either by hy-
draulic or by clamshell methods, and remnant deposit areas 3 and 5 were to be
completely or partially removed by truck. At the end of the first season, the
used portion of the containment area would be covered. During the next year, the
lower pools were to be dredged (clamshell dredging/hydraulic pumpout unloading),
and the remainder of the containment area was to be covered and sealed. In
addition, the temporary earthen basins on the containment site would be demoli-
shed and these areas regraded. The full-scale alternative will remove approxi-
2-12
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mately 44 to 49 percent of the PCBs from the river and will result in the trans-
port of 47,500 kg^Ji.04,800 Ib) of PCBs into the estuary over the next 21 years
(Table 2-6).
5. DREDGING ALTERNATIVESTHE REDUCED-SCALE PROJECT
A preliminary review of the costs associated with the original proposal
indicated that, in order to meet the federal funding limitation imposed by Con-
gress, major elements of the original project would have to be deleted. Accord-
ingly, NYSDEC and its consultants proposed a reduced scale project that modified
the original project by reducing the number of hot spots to be dredged and
reducing the capacity of the containment site (Appendix B). The Thompson Island
Pool was selected as the first pool to be dredged because the cost analysis
indicated that this pool had the lowest transportation and treatment costs per
pound of PCBs removed. In addition, PCB locations and concentrations have been
studied to a greater detail in this pool than in any other.
Under the reduced scale project, final selection of the hot spots to be
dredged in the lower pools would await the results of the proposed probing
and sampling program to be implemented in 1981. It appears at this time that
between 119,000 to 203,000 cu m (155,000 to 265,000 cu yd) of contaminated
material could be dredged in the lower pools within the budget constraints.
This volume can be better defined after the first season of Thompson Island Pool
dredging. The reduced scale alternative will remove approximately 30 to 35
percent of the PCBs from the river and will result in the transport of 61,200 kg
(135,000 Ib) of PCBs into the estuary over the next 28 years (Table 2-7).
The original project deferred final selection of the dredging methodology
until after the competitive bidding for the dredging. However, the reduced scale
project cost constraints may dictate the use of a clamshell dredge with hydraulic
pumpout systems in the Thompson Island Pool in order to ensure that sufficient
funds remain to allow construction and amortization of special equipment that
would be required for lower pools.
2-13
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Table 2-6
PCB Transport: Full-Scale Alternative
Period
1977 to 1978
1979 to 1983
1984 to 1985
1986 to 2001
After 2001
Average Annual PCB
Load at Troy
kg/yr (Ib/yr)
3,600 (8,000)
3,270 (7.200)3
3,270 (7,200)3
1,950 (4,300)
0 (0)
Condition
Before remnant deposit
actions
5 years until full-scale
action is completed
2 years additional to
exhaust supply above
Lock 7
16 years additional to
exhaust supply between
Lock 7 and Troy
Supply exhausted above
Troy
1981 to 2001: 47,500 kg (104,800 Ib) of PCB transported into estuary.
Notes: 1. Assumes 45 percent removal of PCBs from river by full-scale action.
Assumes volatilization rate of 680 kg/yr (1,500 Ib/yr) of PCBs from
the upper Hudson River before full-scale action is completed. This
rate is the average volatilization between 1981 and whatever year no
PCBs remain in the upper Hudson River, or 1/2 the current volatili-
zation rate.
Assumes volatilization rate of 375 kg/yr (825 Ib/yr) of PCBs after
full-scale action is completed.
Assumes routine channel maintenance removal of 1,100 kg/yr (2,500
Ib/yr) of PCBs before full-scale action is completed. This removal
rate is the average rate between 1981 and whatever year no PCBs
remain in the upper Hudson River, or 1/2 the current removal rate.
Assumes routine channel maintenance removal of 625 kg/yr (1,375
Ib/yr) of PCBs after full-scale action is completed.
2. Loadings do not reflect yearly fluctuations of river discharges
and variations of the PCB mass transported.
3. Assumes contribution from remnant deposit is negligible.
2-14
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Table 2-7
PCS Transport:: Reduced-Scale Alternative
1
Period
1977 to 1978
1979 to 1983
1984 to 1985
1986 to 2008
After 2008
Average Annual ECB
Load at Troy
kg/yr (Ib/yr)
3,600 (8,000)
3,270 (7,200)3
3,270 (7,200)3
1,950 (4,300)
0 (0)
Condition
Before remnant deposit
actions
5 years until reduced-
scale action is
completed
2 years additional to
exhaust supply above
Lock 7
23 years additional to
exhaust supply between
Lock 7 and Troy
Supply exhausted above
Troy
1981 to 2008: 61,200 kg (135,000 Ib) of PCB transported into estuary.
Notes: 1. Assumes 30 percent removal of PCBs from river by reduced-scale action.
Assumes volatilization rate of 680 kg/yr (1,500 Ib/yr) of PCBs from
the upper Hudson River before reduced-scale action is completed. This
rate is the average volatilization between 1981 and whatever year no
PCBs remain in the upper Hudson River, or 1/2 the current volati-
lization rate.
Assumes routine channel maintenance removal of 1,100 kg/yr (2,500
Ib/yr) of PCBs before reduced-scale action is completed. This removal
rate is the average rate between 1981 and whatever year no PCBs remain
in the upper Hudson River, or 1/2 the current removal rate.
Assumes volatilization rate of 475 kg/yr (1,050 Ib/yr) of PCBs
after reduced-scale action is completed.
Assumes routine channel maintenance removal of 795 kg/yr (1,750
Ib/yr) after reduced-scale action is completed.
2. Loadings do not reflect yearly fluctations of river discharges and
variations of the PCB mass transported.
3. Assumes contribution from remnant deposit is negligible.
2-15
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6. BANK-TO-BANK DREDGING PROJECT
Bank-to-bank dredging of sediments from the upper Hudson River would require
a much greater amount of equipment operating over several more years than would
the full-scale and reduced-scale proposals. Bank-to-bank dredging would also
require a much larger containment site or several containment sites. These
requirements would make the design difficult to implement and would interfere
with procedures intended to avoid or mitigate adverse environmental impacts.
Much of the dredging"effort would be needlessly expended in removing uncontamin-
ated sediments and disturbing productive wetlands. In addition, bank-to-bank
dredging is estimated to cost over $250,000,000. Based on these concerns,
bank-to-bank dredging is not regarded as a feasible alternative.
II. ALTERNATIVE COMPONENTS
The following sections of this chapter present a discussion of the components
to the major action alternatives. The alternative for in-river containment is
considered to be applicable to certain hot spots where costs and environmental
conditions may make it more desirable than dredging. The remnant deposit
alternatives do not involve dredging, but would be implemented in conjunction
with dredging of the hot spots. Contaminated material removed from the remnant
deposits would be disposed of at the dredge spoil containment site. The other
alternative components, in-river dredging mechanisms and dredge spoil disposal,
are related to the complete or partial removal of remnant deposits and/or hot
spots.
1. IN-RIVER CONTAINMENT
While the removal of PCBs from the river system is the only permanent remedy
for the presently threatening situation, insufficient funds are available to
remove all the hot spots from the river by dredging. Additionally, the dispersed
state of the material and the practical limits of existing technology inhibit
complete removal of the total PCB contaminated river bed material. In-river
containmentthe isolation of shallow areas of PCB-contaminated sediment from the
2-16
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main flow of the riveris proposed as a way to control as great an amount of
PCBs as possible with the funds available. This alternative is intended to be
used in conjunction with a dredging program that would concentrate on the less
stable PCB hot spots.
The PCB hot spots are unevenly distributed along the upper Hudson River.
Some hot spots are located in the main channel of the river; others are located
adjacent to the riverbanks or in protected coves. Only those depositional areas
that are not in the main channel of the river are considered for in-river con-
tainment .
In-river containment can be accomplished by various methods, including
earthen dikes or berms, bulkheads, or sheet piling (Figure 2-2). Dikes or
berms are trapezoid-shaped structures that are built parallel to the river bank
in waters of suitable depth. The PCB-contaminated river bed material contained
between the structure and the shoreline would be .isolated from the river. As an
added precaution, a clay cap could be placed over the contaminated river bed
material. Wetland vegetation would be planted to stabilize the area further.
A less costly variation that may be used for wetland hot spots is a spur dike.
This method consists of riprapping the upstream face of the wetland, then build-
ing a dike off the end of the riprap at an angle to the river flow. This dike
would armor the upper one-third of the wetland against strong flow. Riprap
should be placed at the downstream end of the dike to prevent scouring (Hudek,
USEPA, March 17, 1981). Bulkheading is similar to dikes or berms, except that
pilings and sheetings are used. Sheet piling consists of metal sheets driven
along the face of the hot spot parallel to the flow direction. The metal sheets
interface with one another. Because of the costs, potential navigational
hazards, and difficulties involved with the construction of containment struc-
tures in a dynamic river system, the maximum water depth at which in-river
containment could be used is 2 meters (m) (6 feet [ft]) below mean river stage.
Furthermore, the hot spots selected for such in-river containment must be in
areas with a history of deposition, rather than repeated scouring and aggrada-
tion. Such areas include (1) backwater or eddy deposits formed behind projecting
points of obviously stable land (e.g., with mature tree growth), (2) deposits at
2-17
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the mouths of tributary streams, particularly where they occupy re-entrants in
the wall of the presently active stream valley, (3) areas on the inside of
meander bends where depositional history indicates stability, and (4) areas where
spoil disposal from channel maintenance dredging has resulted in partially
restricted water flow conditions.
In selecting areas for stabilization, strong consideration should be given
to the positions of the 500-year and 100-year flood levels and the possible con-
figuration of the river under these conditions. The tops of structures built for
in-river containment will be at the 100-year flood level. A site should be
rejected if it appears to be unstable under extremely high river flow conditions.
Certain drawbacks are associated with the alternative of in-river contain-
ment as discussed above. A cost comparison between in-river containment and
dredging is presented in Appendix D. Preliminary indications are that costs
involved with berms, dikes, bulkheads and/or sheet piling are approximately equal
to the costs of dredging. However, the structures would need maintenance,
and a long-term water quality monitoring program would be required in the area of
the structures. In addition, a majority of the hot spots are located in areas
where the mean river stage is above 2 m (6 ft).
Another method of in-river containment would be to cover PCB hot spots in
the river (especially deeper pockets) with a plastic liner, silt and rocks.
During low and moderate flows the cover materials might prevent resuspension of
PCBs; but during high flows, the finer material would be scoured and the plastic
liner ruptured, allowing the PCBs to be resuspended.
2. REMNANT DEPOSIT ALTERNATIVES
Remnant deposits are the remains of sediments and debris that accumulated
behind the former dam at Fort Edward. The deposits consist of silt, sand, rock
fragments, sawdust, slabs, and other wood mill wastes. These deposits also
contain contaminants, including heavy metals and PCBs that accumulated in
quiescent areas behind the dam. After the dam was removed in 1973, most of the
accumulated sediments were washed downstream. The five deposits that remained
2-18
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100 YEAR FLOOD-RIVER LEVEL
MEAN RIVER LEVEL
I. BERM OR DIKE
3' HOTSPOT CONTAMINATED DEPTH
100 YEAR FLOOD-RIVER LEVEL
MEAN RIVER LEVEL
MAIN CHANNEL
IK BULKHEAD
3' HOTSPOT CONTAMINATED DEPTH
100 YEAR FLOOD-RIVER LEVEL
MEAN RIVER LEVEL
III. SHEETPILING
3 HOTSPOT CONTAMINATED DEPTH
FIGURE 2-2 IN - RIVER CONTAINMENT ALTERNATIVES
-------
were left above normal river levels because removal of the dam substantially
reduced water levels (MPI, 1980d). Locations of the five remnant deposits are
shown on Plate 2.
From 1974 to 1975, the remnant deposits were subjected to the following
remedial measures:
Work Area No. 1: No action
Work Area No. 2: Bank shaping and seeding of 730 linear m (2,400 linear
ft)
Work Area No. 3: Bank shaping, placement of rock from timber cribs,
and seeding of 600 of 950 linear m (2,000 of 3,100 linear ft) of bank
subject to scour
Work Area No. 4: Bank shaping, placement of rock from timber cribs,
and seeding of 600 linear m (2,000 linear ft).
Work Area No. 5: Bank shaping, placement of dumped rock fill, and seeding
of 340 linear m (1,100 linear ft)
During April, 1976, a once in a 100-year flood caused an additional 200,000
cu m (260,000 cu yd) of material to be scoured from the Fort Edward Pool.
Remnant deposits 4 and 5 remained intact, but substantial amounts of material
were eroded from deposits 1, 2, and 3. In September, 1978, 10,700 cu m (14,000
cu yd) of material were excavated from deposit 3A and moved to the new Moreau
landfill. These sediments contained an average PCB concentration of approx-
imately 1,000 ug/g (ppm). Additional bank stabilization measures were employed
at deposit 3 (MPI, 1980d).
The remnant deposit sites have been surveyed and sampled by MPI and NYSDEC
to determine the degree and extent of PCB contamination. Estimates of the volume
of contaminated sediments, PCB concentrations and total PCB mass were made, and
the results are presented in Tables 2-8a and 2-8b. The disparity between the two
sets of data may be due to different sampling procedures, laboratory techniques,
or the possible heterogeneity of the deposits (MPI, 1980d).
Despite the discrepancies between the two sets of data in Tables 2-8a and
2-8b, both sets indicate that remnant deposits 3 and 5 contain the highest
concentrations and greatest masses of PCBs. The PCBs in deposits 3 and 5 are
2-19
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Table 2-8a
Estimated Mass of PCS in Remnant Deposits (metric measure)
Deposit
1
2
3
3A1
4
5
Total
1
2
3
3A
4
4A
5
Total
Remove
Remain
Estimates by MPI (1978)
Hectares
2.0
3.3
4.9
4.5
8.2
2.4
25.3
Contaminated
Depth
(Meters)
1.5
1.8
3.0
0.3
0.9
3.0
Contaminated
Vo lume
(cubic meters)
30,800
59,200
148,000
17,700
74,000
74,000
399,500
PCB
(ug/gram)
1
5
200
1,000
10
225
(kilograms]
30
310
30.85Q
14,120
770
17,340
63,420
Estimates by NYSDEC (1980)
1.6
3.2
5.4
2.4
4.9
3.4
1.6
22. 52
0.6
1.5
8.3
0.3
0.6
0.9
2.4
9,900
49,300
123,000
7,400
29,600
31,400
39,500
290,100
20
5
65.3
1,000
25
40
250
d (Area 3A)
ing
200
26,0
8,420
7,720
770
1,320
10,280
28,970
7,720
21,250
Notes: 1. The actual 3A area and volume removed in the Fall of 1978 was
3.3 ha and 10,700 cu m.
2. Acreage recalculated by NYSDEC to include only areas known to be
contaminated.
Source: MPI, 1980d
2-20
-------
Table 2-8b
Estimated Mass of PCB in Remnant Deposits (English measure)
Deposit
1
2
3
3A1
4
5
Total
1
2
3
3A
4
4A
5
Total
Remove
Remair
Estimates by MPI (1978)
Acres
5
8
12
11
20
6
62
Contaminated
Depth
(Feet)
5
6
10
1
3
10
Contaminated
Volume
(cubic yards)
40,300
77,400
193,600
17,700
96,800
96,800
522,600
PCB
(ppm)
1
5
200
1,000
10
225
(pounds)
70
680
67,950
31,100
1,700
38,200
139,700
Estimates by NYSDEC (1980)
4.0
8.0
13.3
6.0
12.0
8.5
4.0
55. 82
2
5
7.5
1
2
3
8
12,900
64 , 500
160,900
9,700
38,700
41,100
51,600
379,400
20
5
65.3
1,000
25
40
250
:d (Area 3a)
ling
450
570
18,550
17,000
1,700
2,900
22,650
63,820
17,000
46,820
Notes: 1. The actual 3A area and volume removed in the Fall of 1978 was
8.15 a and 14,000 cu yd.
2. Acreage recalculated by NYSDEC to include only areas known to
contaminated.
Source: MPI, 1980d
be
2-21
-------
largely positioned above normal river levels and have concentrations greater than
50 ug/g (ppm). These deposits are therefore fairly suitable for either stabili-
zation or removal. Remnant deposits 1, 2, 4, and 4A contain lower concentrations
of PCBs, below 50 ug/g (ppm), and relatively small total masses of PCBs (MPI,
1980d). Remnant deposit 4A is low enough in elevation to be subject to yearly
flooding and scouring. Remnant deposit 1 is an island with unstabilized banks
and consequently, is subject to erosion. Remnant deposit 2 has had limited bank
improvement and may also be subject to erosion (Tofflemire, 1980).
At present, exact quantities of PCBs leaching or otherwise lost to the river
from these deposits are unknown. Of the estimated 3,300 kg (7,200 Ib) of PCBs
currently passing over the Troy Dam each year, the LMS model attributes 730 kg
(1,600 Ib) to losses from the remnant deposits (LMS, 1979). River monitoring at
Rogers Island, immediately below the remnant deposits, indicates an annual
downstream PCB transport of 590 to 1,300 kg/yr (1,300 to 2,900 Ib/yr), on the
same order as the LMS loss projections (MPI, 1980d). MPI (1980d) has estimated
that PCB losses from the remnant deposits by means other than volatilization are
negligible because they have either been stabilized and are not being scoured,
or, as with deposit 1, have a relatively low PCB concentration. MPI (1980d)
suggests that an unknown upstream source of PCBs, such as an uncharted dumpsite,
a sewage discharge, or a direct industrial discharge, is contributing to the
present load of PCBs passing Rogers Island.
Tofflemire (1980) projected PCB losses of 200 to 460 kg/yr (440 to 1020
Ib/yr) from the remnant deposits, primarily from deposits 1, 2, 4 and 4A.
Deposits 3 and 5 were considered to be stable, accounting for less than 2.3 kg/yr
(5 Ib/yr). Tofflemire (1980) estimated that erosion could remove PCBs at rates
of 45 to 130 kg/yr (100 to 280 Ib/yr) from deposit 1, 60 kg/yr (136 Ib/yr) from
deposit 2, and 45 to 270 kg/yr (100 to 600 Ib/yr) from deposits 4 and 4A.
Projections of PCB losses were based on the assumption that the deposits would be
eroded in time spans of 5 to 30 years. Currently, some of the sand and wood
chips eroded from the remnant deposits may be accumulating on the north tip of
Rogers Island, in the east channel adjacent to the island, and in the vicinity of
buoy 212. Approximately 75,000 cu m (98,000 cu yd) of material was dredged from
the channel in 1979. Thus, according to Tofflemire (1980), sediments from the
2-22
-------
remnant deposits are still eroding, but it is uncertain which deposit contributes
the most PCBs.
To date, NYSDEC has not identified the source of the large quantities of
PCBs being measured at Rogers Island. It remains to be determined whether or not
the remnant deposits are releasing substantial amounts of PCBs to the river.
PCBs could escape from the remnant deposits by several mechanisms (MPI,
1980d):
scour during high flows (reduced by bank stabilization measures employed
to date)
precipitation that infiltrates the deposits, desorbs PCBs and subsequent-
ly passes into the river as contaminated leachate
runoff from the surrounding terrain, that infiltrates the deposits
and desorbs PCBs, and/or erodes the surface deposits
regional groundwater movement through the deposits that may desorb
PCBs en route to the river
floods that saturate the deposits and. subsequently recede, carrying
particle-bound and desorbed PCBs
Dust-borne transport by wind during dry periods
PCBs are also released from remnant deposits by volatilization. NYSDEC
estimates that 130 kg/yr (280 Ib/yr) of PCBs volatilize from the five deposits,
representing a long-term, low-level source of atmospheric PCBs. Other PCB losses
from the remnant deposits may occur by microbial degradation within the contam-
inated deposits and biological uptake to the terrestrial system (MPI, 1980d).
An additional loss of PCBs from the remnant deposits could occur if a
surging dam were constructed at Fort Edward. The Niagara Mohawk Power Company
(NMPC) has considered construction of such a dam to produce hydroelectric power.
t
If the Fort Edward Dam is rebuilt and the deposits are inundated, four additional
loss mechanisms to the river may occur (MPI, 1980d):
erosion during the construction phase
scour of the deposit surfaces during high flow
biological uptake to aquatic system
saturation and subsequent drainage of contaminated deposits that are
subject to the fluctuating pool levels
2-23
-------
The proposed alternatives for dealing with the remnant deposits are:
(1) no action, (2) denial of access, (3) in place cover, and (4) complete or
partial removal. The purpose of the action would be to reduce or eliminate
possible losses of PCBs from the deposits to the environment. Ongoing PCB losses
and potential losses from high-flow periods must be considered.
2A. No-Action
Under this alternative component, no remedial work would be undertaken
beyond the bank stabilization, seeding, and material removal already completed
between 1975 and 1978. Any present losses of PCBs to the river as well as
volatilization of PCBs to the air would continue. There would be no protection
against losses from high river flows or long-term erosion. The no-action alter-
native component is currently proposed as part of the reduced scale project
(Appendix B).
2B. Denial of Access
At present, several hot spots are easily accessible to the public from the
land, and some are accessible by boat. There is evidence that children occasion-
ally play on some of the deposits and that motorcycles are driven over them.
Animals also have free access to the sites. Human and animal activity at the
sites may accelerate erosional processes and create a potential health risk. The
following measures would be taken under this alternative:
placement of chain link fences, at least 2 m (6 ft) high, topped with
barbed wire, and buried 0.6 m (2 ft) into the ground, on the landward
sides of all remnant deposits
placement of signs facing the water as well as the land at all remnant
sites to warn people that the area contains toxic wastes
continued maintenance of the fence and signs
seeding of ground disturbed by the work described above and other unvege-
tated areas with appropriate grasses
workers would have to take necessary precautions while at the sites,
such as the wearing of respirators and protective clothing
This alternative would do little to reduce present losses of PCBs to the
water and air and would not prevent potential losses from high flows and long-
term erosion.
2-24
-------
2C. In-Place Containment
This alternative would entail further bank stabilization and emplacement of
an impermeable cover, such as plastic or clay, anchored by a protective blanket
of graded material designed to withstand maximum expected flow velocities during
floods (MPI, 1980d). Complete encapsulation would also involve placement of a
curtain wall to prevent groundwater infiltration and desorption of PCBs.
Total amount of capping material needed, the thicknesses of the impermeable
layer, the protective blanket of graded materials, and other construction re-
quirements, as well as costs, are presented in Appendix D.
This alternative component would require extensive construction. Roads
would have to be built to the sites for the transport of materials. In-place
stabilization and capping of deposits 3 and 5 would require 5,000 to 10,000 truck
trips to bring materials to the sites (MPI, 1980d).
Implementation of this alternative component would substantially reduce any
possible losses of PCBs to the river. It would also protect against scouring
during high-flow periods. Volatilization would be essentially eliminated, as
would release through airborne dust and biological pathways.
If a surging dam were constructed at Fort Edward, this alternative would
not prevent losses of PCBs once the deposits became submerged. Fluctuations
in water levels and water turbulence behind the dam would eventually destabilize
the remnant deposits even if they are capped.
This alternative would require a continual maintenance and monitoring
program. It would not prevent any long-term erosional changes of the river
channel. The remnant deposits would remain a potential, long-term source of
PCBs to the river environment.
2D. Complete or Partial Removal
Excavation and upland containment of all remnant sites would entail movement
of 280,000 cu m (370,000 cu yd) of contaminated material containing some 21,200
kg (46,800 Ib) of PCBs. Transport of this material would require 20,000 to
40,000 truck trips. In-place stabilization would not be attempted. This alterna-
tive would be difficult to implement and would include removal of materials with
2-25
-------
low levels of contamination. This component would not be cost-effective because
it would increase sediment removal volume by 74 per cent while increasing PCB
removal mass by only 14 percent, as compared with the partial removal alterna-
tives described below (MPI, 1980d).
The advantage of the complete removal alternative is that it would effec-
tively remove an estimated one-seventh of all PCBs believed to be in the Hudson
River. It would effectively eliminate all future losses of PCBs from the remnant
deposit areas to the river and air, which is especially important if the remnant
deposits are the presently unknown source of PCBs in the upper Hudson River.
Complete Removal of Deposits 3 and 5
In the draft SEQRA EIS (MPI, 1980d), NYSDEC proposed to remove approximately
162,500 cu m (212,500 cu yd) of contaminated material, containing roughly 18,500
kg (41,000 Ib) of PCBs from deposits 3 and 5. This material would be transported
by truck to the PCB containment site located 4.8 km (3 mi) to the south. Ap-
proximately 11,000 to 22,000 truck trips would be required to remove the mater-
ial. NYSDEC proposed no additional remedial measures for deposits 1, 2, and 4,
which contain relatively low levels of contamination. However, deposit 4A,
containing 1,300 kg (2,900 Ib) of PCBs at an average concentration of 40 ug/g
(ppm), may be contributing PCBs to the water column, and could be excavated or
stabilized further as part of future remedial work in the area. If excavation of
area 4A were to be included as a component of the overall project, the removal
volume would total roughly 193,900 cu m (253,600 cu yd) (MPI, 1980d).
Removing deposits 3 and 5 under this alternative would be advantageous
because:
they contain the highest concentration and mass of PCBs in the Hudson
River
in place, they represent a potential long-term source of contamination to
the lower Hudson River
substantial volatilization occurs from them
the cost per pound of PCB removal from the deposits is lowest of any
contaminated area in the river
2-26
-------
Partial Removal Areas 3 and 5
Two partial removal alternatives for deposits 3 and 5 were considered by
NYSDEC and LMS. Under each, removal volumes would be decreased and PCB recovery
would be somewhat reduced. The NYSDEC alternative calls for complete removal of
deposit 5 to a depth of 2.5 m (8 ft), recovering about 10,300 kg (22,650 Ib) of
.PCBs with 39,500 cu m (51,600 <:u yd) of material. At deposit 3, the top 0.5 m
(1.5 ft) and/or all material above an elevation of 40 m (134 ft) would be re-
moved, as would all material down to the present water table at the southern 0.6
ha (1.4 a) of the area. Borings taken by MPI at the southern end of deposit 3
indicate that the water table is contaminated in the portion of the deposit.
Removal of surface material from 2.5 ha (6.3 a) plus removal of material down to
the water table at the southern end would total some 16,700 cu m (21,800 cu yd)
and would recover approximately half of the PCBs in deposit 3. A filter fabric
and stone blanket could be placed over the entire 5.3 ha (13.3 a) area should
conditions warrant (MPI, 1980d).
As consultants to NMPC, LMS has proposed removal of all material above an
elevation of 40 m (134 ft) in deposits 3 and 5. Under this proposal, in the
portion of deposit 3 above an elevation of 40 m (134 ft), 7,800 cu m (10,200 cu
yd) of material containing 630 kg (1,380 Ib) of PCBs would be removed. Con-
taminated surface materials below an elevation of 40 m (134 ft) would remain
unexcavated. Nearly all of deposit 5 lies above an elevation of 40 m (134 ft)
and, under this proposal, roughly 26,200 cu m (34,300 cu yd) of material con-
taining 9,400 kg (20,780 Ib) of PCBs would be excavated from a 1.6 ha (3.9 a)
area. Approximately 3,700 to 7,400 truck trips would be required to remove the
material (MPI, 1980d).
The LMS proposal is coordinated with the proposed reconstruction of the
Fort Edward Dam by NMPC. If rebuilt, the dam would create a pool that would
fluctuate between elevations of 40.5 and 42.6 m (136 and 142 ft). Use of the
40 m (134 ft) level permits a conservative estimate of the area exposed to the
rise and fall of the pool. This rise and fall would tend to wash PCBs out of the
deposit and into the water. Excavation to an elevation of 40 m (134 ft) would
remove all contaminated materials subject to this fluctuation (MPI, 1980d).
2-27
-------
The advantages of the partial removal of deposits 3 and 5 are:
about half of the PCB mass of deposit 3 could be removed by excavating
only 13 percent of the contaminated volume
substantially fewer truck trips are needed to remove the material
subsequent lining and capping would seal the remaining PCB in place
The amounts of material and PCBs that would be removed by each of the
remnant deposit removal alternatives are summarized in Tables 2-9a and 2-9b.
2E. Transportation Alternatives
Trucking seems to be the only feasible method of transporting materials the
2.4 km (1.5 mi) to and from the containment site (MPI, 1980d). Truck access to
deposits 3 and 5 would require the use of residential streets. Methods of
transport other than by truck are not feasible. Alternative transport systems
evaluated include:
riverside conveyer
riverside roadway constructed of dumped rock along the bank
barge transport, hydraulic pumpout
pipeline with booster stations
A conveyor would require material rehandling and is unsuitable for certain
materials found at the remnant deposit sites. Barge transport alone is not
feasible because the river is unnavigable above Lock 7. All other alternative
means for transporting the remnant deposit materials mentioned above would have
associated costs 5 to 20 times those of the proposed transport by truck (MPI,
1980d).
3. IN-RIVER DREDGING MECHANISMS
This section will evaluate the three major dredging/transport systems:
clamshell dredging/mechanical unloading
clamshell dredging/hydraulic pumpout unloading
hydraulic dredging and transport
2-28
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Table 2-9a
Remnant Deposit Removal Alternatives (metric measure)
Deposit
1
2
3
3A
4
4A
5
Total
Complete
Removal
All Deposits
cu m kg
9,900 200
49,300 260
123,000 8,420
Complete
Removal
Deposits 3 and 5
cu m kg
-
-
129,900 8,420
Partial
Removal ,
NYSDEC
cu m kg
-
-
16,700 3,760
Partial
Removal
LMS
cu m kg
-
-
7,800 630
7,400 (Removed to upland containment (1978))
29,600 1,300
31,400 1,320
39,500 10,280
290,100 21,780
-
-
39,500 10,280
169,400 18,700
-
-
39,500 10,280
56,200 14,040
-
-
26,200 9,400
34,000 10,030
Notes: 1. Includes removal of. the surface 0.5 m (1.5 ft) of material over 2.5
ha (6.3 a) of deposit 3, 0.9 m (3 ft) cut over southern 0.6 ha (1.4
a) of deposit 3, 5.3 ha (13.3 a) of liner and capping material.
Complete removal of deposit 5.
2. Includes removal of all material to elevation 40 m (134 ft) in deposits
3 and 5. Does not include additional excavation in deposit 5 for
a new hydroelectric dam.
Source: MPI, 1980d.
2-29
-------
Table 2-9b
Remnant Deposit Removal Alternatives (English measure)
Deposit
1
2
3
3A
4
4A
5
Total
Complete
Removal
All Deposits
cu yds Ib
12,900 450
64,500 570
160,900 18,550
Complete
Removal
Deposits 3 and 5
cu yds Ib
-
-
169,900 18,550
Partial
Removal
NYSDEC
cu yds Ib
-
-
21,800 8,275
Partial
Removal
LMS<2)
cu yds Ib
-
-
10,200 1,380 .
9,700 (Removed to upland containment (1978))
38,700 1,700
41,100 2,900
51,600 22,650
379,400 46,800
. -
-
51,600 22,650
212,500 41,000
-
-
51,600 22,650
73,400 31,925
-
-
34,300 20,780
44,500 22,160
Notes: 1) Includes removal of the surface 1.5 foot of material over 6.3 acres
of deposit 3, a 3 ft cut over southern 1.4 acres of deposit 3, 13.3
acres of liner and capping material. Complete removal of area 5.
2) Includes removal of all material to an elevation of 134 ft in deposits
3 and 5. Does not include additional excavation in deposit 5 for a new
hydroelectric dam.
Source: MPI, 1980d.
2-30
-------
In addition, other dredging systems have been evaluated by MPI (1978b,
1980c) and Gahagan and Bryant (1980) and will be discussed briefly.
The following descriptions of the various major dredging alternatives were
obtained from various reports prepared by MPI (1978b, 1980c, 1980d).
3A. Clamshell Dredging/Mechanical Unloading
The clamshell dredging/mechanical unloading system consists of barge-mounted
cranes outfitted with suitable clamshell buckets to excavate the bed material
(Figure 2-3). The excavated material is loaded on hopper scows for transport to
a rehandling area. At the rehandling area, the material is unloaded from the
scows utilizing crawler-mounted clamshell buckets and loaded on sealed-body dump
trucks for transport to the containment site (Figure 2-4). Alternatively, a belt
conveyor system could be used to transport the sediments from the rehandling area
to the containment site. However, the conveyor would have to be protected from
the weather, and spillage may be a problem. The water treatment plant at the
containment site is sized for 3,785 cubic meters per day (cu m/d) (1 million
gallons daily [mgd]) and will treat runoff from the site and any rainwater that
falls on the site. In addition, runoff rainwater from the rehandling area will
be treated.
Because of the quantity of material that will be hauled to the containment
site, approxiately 400 15.3-cu m (20-cu yd) truckloads per day will be required.
Hauling will be a continuous, 24-hr a day operation, and the traffic-routing
problems and environmental impacts will be substantial. In addition, the cost
associated with this system is greater than the other major dredging alterna-
tives. Difficulties associated with handling mud and fine-grained material in the
dredged sediment will hamper the unloading operation. None of the dredging
contractors contacted were interested in unloading the barges mechanically (MPI,
1980d). Consequently, this system was eliminated from further consideration.
3B. Clamshell Dredging/Hydraulic Pumpout Unloading
This system, shown in Figure 2-4, utilizes the same equipment in the river
as described above for the clamshell dredging/mechanical unloading alternative.
At the rehandling area, however, a barge-mounted hydraulic pumpout system will be
used to unload the hopper scows. The pumpout plant can be operated as a once-
2-31
-------
through process or as a recycle system. River or recycled water from the dis-
posal site would be mixed with the sediment in the hopper scows to an average 15
percent slurry. The slurry is then pumped to the disposal area. The water
treatment plant is sized for approximately 37,850 cu m/d (10 mgd) in a once-
through system and 3,785 cu m/d (1 mgd) if pumpout water is recycled. At the
disposal area, the position of the slurry-pipeline discharge and the layout of
the interior dikes would be arranged to facilitate the mixing of fine and
coarse-grained sediments.
The factors that affect the excavation of material from shallow areas with
a clamshell dredge include the weight and configuration of the clamshell bucket,
material stratification and characterization, and caving of the cutting face, as
well as the placement of the bucket and general skill of the operator. If soft
material is encountered, the clamshell bucket can readily penetrate the layers.
The bucket will generally scrape across compacted layers of material that lie
below the contaminated sediments in the hot spots.
The clamshell bucket design can be modified to provide more efficient
excavation and recovery of PCBs. Some modifications that should be considered
in the dredging design phase of the project are:
lateral digging bucket
special seals on the bucket lips
buckets that close completely
shrouded or hooded buckets that would prevent washout of material
during hoisting
Clamshell dredges are readily available and have been used for many years
(Gahagan and Bryant, 1980). Hydraulic pumpout plants have been used both in this
country and in Europe. This system is implementable, and competitive bids could
be submitted because several local contractors are equipped to do the work.
The estimated PCB losses from dredging with this system are presented in
Table 2-10. The total loss is dependent on the magnitude of return water flow.
If pumpout water is recycled and the return water flow is treated by sedimenta-
tion and coagulation, PCB losses from this system are approximately 0.01 percent.
In a once-through process, the return water flow is estimated to be 37,850 cu m/d
2-32
-------
Oiscnarge
Line
Laaoar
Spua (Typ.)
Cuttsrneaa
HYDRAULIC CUTTERHEAD DREDGE
CLAMSHELL DREDGE
Pullovar
Ciolt
-tutu
MUD CAT DREDGE
Figure 2^-3 Dredge Illustrations
Source: MPI, 1980d
-------
ROUGHING & STORAGE POND-
HYDRAULIC DREDGING AND TRANSPORT
/CLAMSHELL DREDGE
D <£
-HOPPER SCOW
REHANOLING AREA
TRUCK HAUL ROA
(CONVEYOR OPTION)
CLAMSHELL DREDGING - MECHANICAL UNLOADING
ROUGHING &
STORAGE PONO
POLISHING
POND
\ (1 MOD)
' RECYCLE WATER
PRIMARY
DISPOSAL
AREA
' 1
,^_
\
\
ROUGHING & STORAGE PONDS-1
CLAMSHELL DREDGING.- HYDRAULIC PUMPOUr
Figure 2- 4 Alternative Dredging Systems
Source: MPI, 1978 b
-------
Table 2-10
PCS Losses Clamshell Dredging/
Hydraulic Pumpout Unloading
Loss Mechanism
Missed during dredging ,
Lost in dredging progress ~
Lost in return water flow at (10 ug/1)
PCB Loss (percent)
5
0.8-4
0.01-0.1
Notes: 1. If the PCB lost in the dredging process does not resettle in down-
stream hot spot areas, the total loss from this mechanism could be 4
percent. However, if 20 percent of the PCBs desorb and the remaining
PCBs resettle in hot spots to be dredged, the loss from this mechanism
could be only 0.8 percent.
2. Treatment by coagulation and sedimentation.
Source: MPI, 1980a.
2-33
-------
(10 mgd), and PCB losses are 0.1 percent. The total PCBs recovered are estimated
to range between 90.9 and 94.2 percent for Thompson Island Pool dredging with
this system. It is believed that these losses will not be exceeded if the
dredging and disposal operations are carefully controlled. Lab work is currently
underway to determine more accurately the effluent PCB concentrations to be
expected with sedimentation-cpagulation treatment.
3C. Hydraulic Dredging and Transport
The equipment utilized in a hydraulic system would be a conventional cutter
head suction dredge assisted by boosters, tugs, barges, and miscellaneous equip-
ment (Figure 2-3). Material would be transported by floating or submerged
pipeline to the shoreline (Figure 2-4). A channel trench for sections of sub-
merged pipe might be necessary to avoid any obstruction to navigation. A
hydraulic dredging operation in the Thompson Island Pool would require one
booster station. Removal of lower pool hot spots by this method would require a
number of booster stations and an unwieldy pipeline system. Because of high
costs associated with booster stations and long pipelines, this system is appli^-
cable only to work in the Thompson Island Pool.
The slurry would be pumped on land from the river to the containment
site. It would be necessary to install the pipeline beneath U.S. Route 4.
At the disposal area, the slurry discharge and dikes would be arranged as de-
scribed for the clamshell pumpout alternative to facilitate mixing of fine
and coarse-grained material. The water treatment plant would be sized for
approximately 37,850 cu m/d (10 mgd).
Equipment required would include one 40-cm (16-in) hydraulic cutter head
dredge, one derrick barge, two 40-cm (16-in) booster pumps, two bulldozers, one
small tug, one tender tug, one fuel barge, one work barge, pipeline, and miscel-
laneous machinery (Gahagan and Bryant, 1980).
This system offers the advantage of one-time handling of the material
between the dredging operation and the disposal area. For the Thompson Island
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Pool, the system is economically competitive with a clamshell dredging/hydraulic
pumpout system. Hydraulic dredges of this nature are in regular use on the
Hudson River by the NYSDOT and others, and no difficulty is expected in securing
equipment of this type.
The design of hydraulic dredges must be modified to improve PCB recovery
efficiency by:
installation of a shroud to enclose the top portion of the cutter
use of sensor devices to control depth of cut over an uneven bottom
modification of the conventional cutterhead dredge by installing a
dustpan-type head
These modifications will be considered and incorporated as appropriate in
the dredging design phase of the proposed project.
The estimated PCB losses expected with the hydraulic dredging and transport
system are presented in Table 2-11. For hydraulic dredging, the loss from return
water flow is larger than for the clamshell dredging/pumpout system with recycle
of return water because of the larger flow requiring treatment. For Thompson
Island Pool dredging, the average return water flow will be 37,850 cu m/d (10
mgd) as compared to 757 cu m/d (0.2 mgd) with the pumpout recycle system. The
loss in return water flow with sedimentation and coagulation treatment is
estimated at 0.1 percent and is not significant when compared to the other loss
mechanisms. Therefore, the total PCBs recovered are estimated to range between
95.9 and 97.5 percent. It is believed that these losses will not be exceeded if
the dredging and disposal operations are carefully controlled. As stated pre-
viously, lab work is underway to define more clearly the effluent PCB concentra-
tions with sedimentation-coagulation treatment.
3D. Other Dredging Systems
Several other dredging systems have been evaluated by MPI and Gahagan and
Bryant, and the difficulties with these alternative systems, including the
reasons for their rejection as primary dredging systems, are summarized below:
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Table 2-11
PCB Losses; Hydraulic Dredging and Transport
Loss Mechanism
Missed during dredging .
Lost in dredging process
Lost in return water flow at (10 ug/1)
PCB Loss (percent)
2
0.4-2
0.1
Notes: 1. If the PCB lost in the dredging process does not resettle in down-
stream hot spot areas, the total loss from this mechanism could be 2
percent. However, if 20 percent of the PCBs desorb and the remaining
PCBs resettle in hot spots to be dredged, the loss from this mechanism
could be only 0.4 percent.
2. Treatment by coagulation and sedimentation.
Source: MPI, 1980a.
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Mud cat dredge: low capacity, limited pumping distance, and inability
to deal with large debris. This dredge is illustrated in Figure 2-3.
Although not applicable to the whole project, it does have advantages for
limited work in shallow areas.
Dustpan type dredge: difficulty with large debris, ineffective with an
uneven bottom, and requires use of water that might cause PCS dispersion.
Not presently available, although a conventional hydraulic dredge could
be modified to operate as a dust pan. The Norfolk (Virginia) District
of the USACOE proposed to carry out a demonstration project with a con-
verted dredge in 1981.
Pneumatic dredge: limited pumping distance, limited capacity, difficul-
ties with large debris, limited availability, and poor fuel economy.
Reported capacities of approximately 60 cu m/hr (2,000 cu ft/hr) for one
proprietary type would quadruple cost of dredging.
Backhoe or dragline dredge: difficulties with bucket roll that could
cause displacement of PCBs, imprecise control of dragline bucket, and
turbidity.
Cable excavator: requires extensive operations on the shoreline, is
difficult to control, and causes turbidity and dispersion of PCBs.
Pumping into scows: poor economically because of large volume of water
to be transported and rehandled.
Bucket ladder dredge: not available; causes dispersion of sediments.
These systems may be applicable for hot spots in shallow areas or other
inaccessible locations.
4. DREDGE SPOIL DISPOSAL
Associated with any dredging alternative is disposal of the dredge spoil.
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Two alternatives are considered for the disposal of the contaminated material.
One alternative involves the ultimate disposal of the dredge spoil through a
detoxification method. The other option is land disposal in a secure containment
facility. NYSDEC screened 40 potential sites in the upper Hudson River area and
selected a tract of land located 4.0 km (2.5 mi) south of the Village of Fort
Edward. On this site an earthen structure will be built to contain the con-
taminated sediments. This site is intended for temporary disposal of the dredge
spoil until an economical ultimate disposal method is developed. The criteria
used for site selection assumed indefinite long-term storage to ensure site
safety.
4A. Detoxification
Alternatives evaluated under this section included:
physical destruction through incineration
chemical treatment
biodegradation
Currently, physical destruction through incineration is the most effective
and best understood means of ultimately destroying liquid PCBs. Most of the
systems used, however, remove PCBs in the liquid phase and are not suitable for
PCB-contaminated sediments. The systems require high temperatures (1,148 C
[2100 F]) and carefully calculated detention times in order to minimize impacts
to air quality.
During research of different alternatives, GE, with the assistance of
NYSDOT, collected contaminated sediments and sent them to a pyrolysis system
in New Jersey. The conclusion of this study (Nichols Engineering and Research
Corporation, 1978) were as follows:
PCB-contaminated Hudson River bottom sediment can be decontaminated by
heating the solids in a multiple-hearth furnace to a temperature of about
537°C (1,000°F).
Both incineration and pyrolysis are successful methods of decontamination.
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Pyrolysis is preferred over incineration for toxic heavy metals retention
in the solid phase. Scrubbers are relatively ineffective for reducing
the air pollution discharges of heavy metals, particularly cadmium and
lead, from incinerator stacks (Farrell and Wall, 1981).
Afterburner temperatures between 871° and 982°C (1600° to 1800°F)
will be required to destroy the volatilized PCBs.
The cost for this type of incineration of PCB-contaminated dredge spoils has
been estimated to be approximately $130/cu m ($100/cu yd), including construction
of dewatering equipment and an incinerator (MPI, 1980d). Because of the large
volume of materials that would have to be processed, incineration of contaminated
Hudson River sediments is economically infeasible. Incineration costs for dredge
spoils, not including dredging and transportation costs, would exceed
$200,000,000 for the full-scope plan and $80,000,000 for the revised plan.
The cost for pyrolysis is comparable to the cost for incineration.
Other systems capable of incinerating PCBs exist. The Wright Malta Corpora-
tion (1979) claims to have developed a bench-scale steam gasification process
that may potentially convert PCBs into relatively innocuous by-products such as
fuel gas and salt. However, this process has been demonstrated to be applicable
to PCB-contaminated sediments on a laboratory basis, and the effectiveness and
economics of this system have not: yet been justified.
Rollins Environmental Services in Deer Park, Texas, and Energy Systems
Company in El Dorado, Arkansas have received permits to incinerate waste con-
taining PCBs as of April, 1981 (Jordan, Rollins Environmental Services, February
26, 1981). At present, their system will handle only liquid wastes, and costs
have been estimated to range from $0.06 to $0.99/kg ($0.03-$0.45/lb) of waste.
Currently, chemical and biological degradation of wastes are not well proven
and remain at the laboratory stage. Chemical degradation has been successful
with pure PCBs in laboratory studies (MPI, 1980d), but large-scale degradation
has not yet been proven feasible. A chemical process has been developed by the
Goodyear Tire and Rubber Company (Goodyear, 1980) that reacts sodium metal with
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PCBs at high temperatures (350 C [662 F]). The process is slow and is carried
out in an autoclave. It is still in the laboratory stage and is not feasible
for the Hudson River sediment at this time.
Biological degradation of some PCBs (the lower aroclors) has been found to
be successful by GE. Five types of microorganisms demonstrated the ability to
degrade PCBs. Much work, however, is still required before a suitable micro-
organism is found that can degrade PCBs in a reasonable time span.
Sunohio has developed a process called PCBX that has been demonstrated to
detoxify typical transformer oil and may be suitable for other PCB-contaminated
oils (Sunohio, 1980). This process is not designed to detoxify PCB-contaminated
river sediments.
4B. Containment in Upland Disposal Site
Because of the limitations associated with dredge spoil detoxification,
a site for a secure containment facility was sought (MPI, 1980a). MPI evaluated
the regional geology, hydrology, soils, land use, and development patterns in the
upper Hudson River Valley in an attempt to find a suitable location for a con-
tainment facility. A screening methodology was developed that incorporated
federal and state regulations for secure land burial facilities, the nonavail-
ability of mineral resources that may be mined at some future date and site
preparation requirements to achieve acceptable conditions in an economical
manner. The process used in applying this methodology and the site screening
criteria are described in various MPI reports (1978b, 1978b, 1980d).
Initial screening resulted in 40 potential parcels that were subsequently
reduced to 12 sites. Field inspection further reduced the number of potential
sites to 4. After detailed screening of the environmental and socioeconomic
factors present at each site, one site was selected. This site is identified as
Site 10 and is located 4.0 km (2.5 mi) south of the Village of Fort Edward. The
tract consists of three parcels totaling approximately 100 ha (250 a) bisected
by a north-south oriented power line right-of-way. Access to the property is
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from Route 4 to the west. Elervations at the site range from 55 m (180 ft) in
the northwest to 40 m (130 ft) in the southeast along Dead Creek. Most of the
site is at elevations between 44 and 47 m (145 and 155 ft). Detailed comparisons
of the final 4 candidate sites are contained in various MPI reports (1978b,
1980a, 1980b).
Upon selection of Site 10 as the location for the containment facility, a
detailed geotechnical and environmental study was performed on the site (MPI,
1980a). The field investigation indicated that subsurface conditions were
adequate to prevent leachate from migrating off-site. Soils found at Site 10 are
characteristically deep, moderately well drained to poorly drained fine-textured
soils. The underlying clays are proglacial lake beds consisting of varved
clays. Laboratory and field tests indicate that the clays are very poorly
permeable. Permeability of the clays ranged from 2.5 x 10 to 5.88 x 10
_ Q _ £.
cm/s (9.8 x 10 to 2.3 x 10 in/s). Additional investigations included 26
borings, four resistivity traverses, and 19 test pits. Information provided by
these surveys indicates that the site is adequate for the secure land disposal of
PCB-contaminated sediments.
With the selection of Site 10 as the land disposal site, a secure contain-
ment facility was designed to encapsulate the contaminated sediments. MPI has
designed engineering structures and control systems to prohibit leachate movement
and provide continuous monitoring during the placement of the dredge spoils and
after closure.
All of the containment dikes, berms, and permanent cap will be constructed
primarily of the silty clay and silty clay loam soils present on the site.
Engineering studies on the soils at the site indicate that this material will
form dikes that are stable if built to design specifications. A seepage
analysis of the dike material indicates that flow would be on the order of
-6 ~4
2.5 x 10 cu m/d/m (3 x 10 cu ft/d/ft). It is estimated that water within
the containment area would require in excess of 1,000 years to reach the outside
face of the dike (MPI, 1980b).
When placed in the proposed containment site, the dredged material will
contain substantial quantities of interstitial water remaining as a result of the
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hydraulic transport process. The rate at which this liquid can be drained is a
function of the permeability of the dredged material, and drainage will take from
1 to 2 years at the maximum. It is estimated that this will produce 344,435 cu m
(91,000,000 gallons [g]) of interstitial water over the 1 to 2 year period.
An alternative method of dewatering the dredge spoils is to use hydrocyclone
separators, diaphragm presses, or other mechanisms. The dewatering spoils
would be deposited in an upland containment site and the water would be dis-
charged to the Hudson River after receiving necessary treatment. This conceptual
alternative is more energy intensive than the alternative to dewater by gravity,
but impacts associated with volatilization of PCBs during dewatering probably
would be substantially less using mechanical methods. However, the engi-
neering feasibility and design of mechanical dewatering have not been deter-
mined. Nevertheless, applying currently available dewatering processes, such as
hydrocyclone separators or diaphragm presses, preliminary estimated indicate that
mechanical dewatering would cause additional costs of more than $5,000,000
(Richard Thomas, Project Manager, MPI, April 21, 1981). Therefore, mechanical
dewatering is presently regarded as not cost-effective.
Long-term rainfall infiltration through the cover could continue to generate
a leachate, estimated to be approximately 8,377 cu m/yr (2,200,000 gal/yr) (MPI,
1980b). A leachate collection system has been designed by MPI for the contain-
ment facility and consists of the following components:
sloped bottom of containment area
gravel-filled collection trenches wrapped with filter fabric
perforated drainage piping in the collection trenches
collection and sampling wells on the containment area perimeter con-
nected to the drainage piping
piping system to connect the drainage system to a discharge point at
the Hudson River
flow metering and monitoring system
The leachate collecting system would be valved. Discharge to the Hudson
River would be permitted only if leachate quantities and concentrations observed
will have no adverse impact on the river.
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Stormwater runoff collection would entail the use of one collector drainage
channel, constructed at the toe of the containment dikes, to convey all off-site
and on-site drainage to the Hudson River. After closure, additional channels
would be constructed both along the south dike and on top of the closed contain-
ment areas. All flow from these channels would be conveyed to the collector
drainage channel by means of drop pipes constructed at various locations around
the containment areas.
All flow from the collection channel, as well as effluent from the treatment
plant, would be conveyed to the Hudson River under Route 4 and the Champlain
Canal by means of a closed conduit (MPI, 1980b).
During each dredging season, the proposed site would receive spoil from the
dredging operations. At this time, the rate at which the dredged material
dewaters will dictate how quickly the cap will be placed. The higher the per-
centage of fine-grained sediments, the slower the material will drain. Recent
data from probings in the Thompson Island Pool indicate that the material will
dewater within two or three weeks of placement. Based upon this initial assump-
tion, the capping material will be spread over the dredged material as dredging
progresses throughout the summer,, This will minimize volatilization.
At the end of the second season, the site will be permanently capped. The
cover will consist of a 46-cm (18-in) thick layer of clay overlain by gravel and
topsoil. Clay material for the cap will be obtained on-site. The cap will be
designed to withstand deterioration by freezing, thawing, and drought. At the
time of permanent closure, all return water treatment structures will be removed
and permanent long-term monitoring and control structures will be installed.
Under the full-scale project, the containment area was designed for a
capacity of 1,728,000 cu m (2,260,000 cu yd) of contaminated material. Under the
reduced-scale project, the required containment volume was reduced owing to
deletion of remnant deposit relocation and containment, deletion of provisions
for NYSDOT spoil area containment, and reduction in hot-spot dredging. For
these reasons, the required containment capacity of the reduced-scale project is
estimated to be 841,000 cu m (1,100,000 cu yd) (Appendix B).
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III. SELECTION OF THE RECOMMENDED ACTION
1. RECOMMENDED ACTION
Based on public health, environmental, cost, and engineering evaluations
carried out by EPA and its environmental consultants, the EPA recommends that the
action alternative be implemented if contingency/mitigation measures ensuring
public safety are developed (Table 2-12).
Resolution of these issues will ensure that minimal risk to public health,
safety, and welfare will result from the implementation of this project Modi-
fications and contingencies developed will be submitted for public comment
before a NEPA decision is reached.
EPA recommends that a project to dredge and/or stabilize all known PCB hot
spots be implemented. After carefully evaluating both the original full-scale
proposal and reduced-scale proposal submittted by NYSDEC, EPA recommends funding
a modification of the original full-scale project since greater potential
benefits will be realized. However, if additional funding is not available, the
reduced-scale project is also recommended, although with reduced potential
benefit, because it will provide for demonstration of river recovery and in-
definite storage while not endangering public health, safety, and welfare.
The authorization by Congress under Section 10 of the CWA Amendments is
$20,000,000. If the action alternative is approved, the recommended action is
to undertake the originally proposed $40,000,000 full-scale project with the
required modifications. Additional funds from either federal, state, or perhaps
outside sources will be required to implement the full-scale project, while
affording protection of the public health and the environment. Although not as
desirable as the full-scale project, it is recommended that the $26,700,000
reduced-scale project could be undertaken along with the aforementioned project
modifications.
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Table 2-12
EPA Recommended Program
Full- Scale
Dredging or in-river containment of all
40 hot spot areas in the river bed with
containment in a secure upland site.
Design and construction of a secure
upland containment site capable of
indefinite long-term isolation of
contaminated material
Deletion of remnant deposit removal and
upland containment; instead, provision of
secure cap and top dressing,and further
bank stabilization if necessary
Elimination of provision for the con-
tainment of PCB-contaminated material
from dumpsites in the Fort Edward area.
Provision for containment of contaminated
materials from three NYSDOT dredge spoil
sites (212, 13 and 204 Annex)
Provision for dredging and containment
operational standards and procedures,
mitigation measures, monitoring programs,
and contingency plans necessary to safe-
guard public health and agricultural
resources
Provision for research studies/environ-
mental monitoring programs necessary
to demonstrate the improvement in the
rate of recovery of the river and
storage of contaminated material
Reduced-Scale
Reduction of the number of hot
spots to be dredged or contained
in-river
Same, except for a reduction in
capacity at the containment site
Same
Same
Same
Same
Same
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2. FINDINGS
1. Disposal of PCB-contaminated dredge spoils in a landfill would provide
a higher standard of protection of the public health, safety, and
welfare than disposal of such pollutants by other methods including,
but not limited to, incineration or a chemical destruction process.
The basis of the above conclusion is that alternative disposal methods
are either infeasible or highly speculative and would render the entire
project economically infeasible within the amounts of money available
for the "rescoped" project (i.e., $26.7 million).
2. The proposed containment site, incorporating the modifications and
safeguards described below, is environmentally sound for indefinite
storage of PCB-contaminated sediments. The storage of contaminated
sediments at the proposed containment site will not have significant
long-term adverse environmental impacts to the surrounding communities.
3. The proposed dredging operation, incorporating the modifications and
safeguards described below, will not have significant short- or long-
term adverse effects on the surrounding community, downstream water
supplies or the ecology of the Hudson River.
4. Removal and in-river containment of substantial quantities of PCB-laden
sediments should demonstrate an improvement of the rate of recovery of
the Hudson River.
5. Removal and in-river containment of PCBs from the upper Hudson River
will also reduce the risk of:
contaminating downriver water supplies caused by high flow conditions
public health threats due to excessive volatilization from the river
bank areas
- public health threats due to the consumption of contaminated fish
the necessity to close the Hudson River fishery due to high flows
after projected reopening
permanent closure of the striped bass fishery
conducting environmentally unsound maintenance dredging and upland
disposal of contaminated sediment from the upper Hudson River and
estuary
closing navigable waterways both in the upper and lower Hudson River
due to the inability to provide adequate upland containment of
containment dredge spoil
endangering aquatic species, in particular the shortnosed sturgeon.
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6. Removal and in-river containment of PCBs from the upper Hudson River
is not expected to significantly reduce PCB sediment concentrations
in the New York Harbor.
7. As presently proposed by NYSDEC, PCB volatilization caused by the
discharge of contaminated dredged sediment into the containment site
could exceed the New York State Department of Health (NYSDOH) recom-
mended maximum allowable 24-hour average ambient air PCB concentration
at nearby residences and at other sensitive receptors under worst case
dissolved PCB concentrations and meteorological conditions. However, the
analysis conducted by EPA shows that with mitigation measures presented
below, the 1 ug/cu m ambient air guideline should not be exceeded.
3. MODIFICATIONS
The modifications to the original project, as well as to the reduced-scale
project referenced above, include changes in the design, operational standards,
contingencies, and long-term monitoring and maintenance. These recommendations
are consistent with the Congressional intent of Section 10 of the CWA Amendments.
The purpose of these modifications is to provide a higher standard of protection
for public health, safety, and welfare during dredging and disposal operations
and throughout the life of the containment site. Prior to the NEPA decision and
granting of federal funds to undertake site construction and dredging, the
modifications described below must be fully developed, submitted for public
comment, and approved by EPA.
Since neither the original or reduced-scale project contains the specific
provisions to carry out financial assurances, contingencies, long-term monitor-
ing, operational standards and procedures, operation and maintenance, or land
acquisition, the NYSDEC must obtain firm commitments for additional funding for
these provisions from either state or other federal sources prior to project
approval. Federal or state matching funds currently appropriated for this
project are not sufficient to be used for these purposes. These current funds
are to be used only for dredging, site construction and closure, and a monitoring
program for only the duration of the project operations. Although there are a
substantial number of modifications and additions to the original full-scale and
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reduced-scale projects, most are directed toward long-term elements subsequent
to containment site closure, the costs of which are to be borne by New York
State. Therefore, the modified project should not substantially reduce the
material planned to be removed from the river.
The recommended modifications to the project are specified below under the
separate categories of "Dredging, In-River Containment, and Stabilization",
"Disposal", "Long-Term Storage", and "Water Quality Monitoring".
Dredging, In-River Containment, and Stabilization
1. Study and make recommendations to maximize in-river containment of hot
spots where feasible and cost effective. (This will be studied in
detail during the 45-day draft NEPA EIS review period).
2. Cap/in-place stabilization and denial of access of remnant deposits
3 and 5 as an immediate measure.
3. Maximize upriver flow regulation at Sagandaga Dam as a flood control
measure during the dredging operation.
4. Develop operational standards and procedures, mitigating measures,
monitoring programs, and contingency plans to eliminate excessive
volatilization and resuspension of PCB-contaminated sediments to
protect workers, residents, agricultural resources, and water supplies.
Disposal
1. Modify disposal operations at the containment site including the
provision for smaller containment cells, addition of PCB adsorbents,
and possible cell cover during loading operations to minimize vola-
tilization.
2. Develop operational standards and procedures, contingency plans, and
monitor program surrounding the proposed containment site for the
duration of the disposal operations to assure the NYSDOH 1 ug/cu m
ambient air guideline is met, as well as the 0.2 ug/g (ppm) standard for
crops set by the FDA
3. Develop specific contingency plans for additional treatment of the
supernatant from dewatering prior to discharge if permit limits (to be
established) are exceeded.
Long-Term Storage
1. Development of long-term maintenance and monitoring programs for a
minimum of 30 years with periodic program review by EPA and NYSDOH.
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2. Contingency plans for (a) long-term leachate collection and treatment,
(b) landfill cap maintenance, (c) excessive PCB volatilization or
methane generation, and (d) alternate water supply should monitoring
indicate failure of containment site.
3. The development of grievance and arbitration procedures and the investi-
gation of the feasibility of liability insurance for any claims arising
in connection with the public health aspects of the project.
4. Provision for specific funding mechanisms by NYSDEC to assure imple-
mentation of long-term contingency plans, operation, maintenance, and
monitoring.
5. Redesign of the containment site leachate collection and storage system
to improve operations and to avoid clogging and buildup of leachate
within the site.
6. Provision for storage of NYSDOT maintenance dredging materials from
sites 212, 13, 204 Annex from Washington County only (if removal is
deemed necessary), under the condition that the state bear the incre-
mental costs associated with disposal and long-term storage.
Water Quality Monitoring
1. Develop a long-term monitoring program to evaluate the improvement of
the recovery rate of the river and fisheries.
2. Develop a long-term monitoring and maintenance program if in-river
containment is implemented to determine leaching of PCBs back into
the river.
3. Develop a downstream public water supply monitoring program for
PCBs and heavy metals to be implemented before, during, and after
dredging operations, especially during and shortly after high flows.
Contingency plans to provide additional water treatment or alternate
water supplies also should be developed.
4. Develop a short-term monitoring program for air quality, water quality,
and biota during dredging and disposal operations.
4. CITIZEN INVOLVEMENT
It is also recommended that if either the full-scale or the reduced-scale
project is undertaken, the CAC and the Settlement Advisory Committee (SAC) be
continued at least through the operational phase of the project, and beyond
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if so desired by the respective committees. The committees would serve as a
community focal point for the distribution of project information and data and,
at the same time, provide oversight and local and technical liaison between the
affected communities and the operational and regulatory agencies, including EPA.
The CAC has raised two issues of public concern which should be considered
by New York State.
1. NYSDOT should develop a comprehensive PCB dredge spoil disposal
plan for the upper Hudson River, also within the same time frame
as this proposed project.
2. NYSDEC should consider providing assurances that neither the pro-
posed containment site nor the surrounding land acquired by New
York State will be used for the future disposal of any hazardous
waste generated from either within or outside Washington County.
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CHAPTER 3
Affected Environment
(Existing Conditions)
-------
CHAPTER 3
AFFECTED ENVIRONMENT (EXISTING CONDITIONS)
This chapter presents descriptions of the natural and man-made environmental
resources that may be affected by the alternatives under consideration.
1. EARTH RESOURCES
la. Regional Geological Setting
Bedrock Geology
Geological units in the region are composed of both consolidated and un-
consolidated materials. The area is underlain predominantly by shales with
minor occurrences of slate and graywacke. Blue-black to gray clayey shale
layers (a few inches to several feet thick) and some sandstone layers (rarely
more than 8 cm [3 in] thick) make up the shales. These bedrock formations, as
observed in outcrops and borings in the area, dip toward the southeast. In areas
of jointing and fracturing, many fractures are tightly sealed with calcium
carbonate. However, the remaining open joints and fractures allow the migration
of water.
Surficial Geology
In most places, the bedrock is overlain by unconsolidated glacial materials
and more recently deposited materials ranging in depth from a few inches at
rock outcrops to more than 60 m (200 ft). The identifiable unconsolidated
sediments are: (1) glacial till, (2) glacial outwash, (3) ancient lake deposits,
(4) recent river deposits, and (5) modern dredge spoils.
The glacial deposits are the result of the Wisconsin Age glacial advancement
that eroded and smoothed the bedrock surface during the Pleistocene Epoch.
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Glacial till deposits, which cover approximately 10 percent of the upper Hudson
basin are highly variable assortments of rock materials ranging in size from
clay particles to rock fragments and boulders. The till usually occurs as
ground moraines of varying thickness. Generally, the till is not stratified but
local pockets of sand, gravel, silt, and clay do occur within the till mass.
Deep till deposits tend to be more compact and dense than shallow deposits that
have been weathered more completely (MPI, 1978a).
Glacial outwash deposits consist of sand and gravel sorted by glacial melt
water. These deposits are generally younger than, and commonly rest on, till.
Valley-fill deposits were formed in lakes or stream channels where spillways
were formed by ice or glacial debris. Approximately 25 percent of the upper
Hudson River area is overlain by glacial outwash. Outwash deposits occur in
most stream valleys tributary to the Hudson River. The thickness of the de-
posits is influenced by the shape and original bedrock of the valleys. These
highly variable sediments are usually stratified, consisting of gravel, coarse
through fine sand, and clay. Deltaic deposits are fan-shaped outwash formations
that were generated at points where streams laden with large rock debris entered
the still waters of proglacial Lake Albany. Deltaic deposits are composed of
materials ranging in size from coarse gravel to fine sand and silt (MPI, 1978a).
Ancient lake sediments, which occupy up to 60 percent of the upper Hudson
area, were deposited on the bottom of proglacial Lake Albany. This lake ex-
tended from Rensselaer County to Essex County some 10,000 to 15,000 years ago.
These deposits were laid down in the quiet water of the glacial lake and were
eventually exposed as flat terraces or bottomlands when the lake drained, near
the end of the Pleistocene Epoch. Today, the formations are found along the
Hudson River as terraces, covering flat to gently rolling valley floors. The
lower beds are predominantly fine-grained bluish clays grading to yellowish-red
silts (MPI, 1978a).
Recent river deposits, known as alluvium and consisting of sediments of
various textures deposited along streams, occupy less than five percent of the
upper Hudson area. These deposits are usually located on the floodplains within
790 m (2,600 ft) of the banks of the Hudson River and certain tributaries.
3-2
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Canal dredging spoils has been deposited along the Hudson River as a result
of human activity within the study area. These deposits are generally coarse
grained, consisting of quartz-feldspar sands, cinders, and shale cobbles,
mixed with wood fragments ranging from sawdust to pieces several feet long
(MPI, 1978a).
Seismic History
Seismic events recorded in and around the upper Hudson River Basin have
been moderately common, although not excessively damaging. Earthquakes in the
area indicate that- movements are associated with known or closely related
faults. The area is listed in the Zone 2 (moderate damage) seismic risk area.
Algermissen and Perkins (1976) estimate that there is approximately a ten
percent chance that the bedrock units in the area will undergo horizontal
acceleration (shaking) that exceeds nine percent of the force of gravity at
least once in a 50-year period.
Soils
Most of the soils within the upper Hudson River Valley have been formed in
mineral material deposited by the Wisconsin Age glacial advancement, the most
recent glacier of the Pleistocene Epoch. Some soils, however, have been formed
in more recent deposits of alluvium or dredge spoils.
Shallow soils developed in glacial till over bedrock are rare in the area
and are usually found on undulating to hilly uplands. Drainage of these soils
ranges from moderately well drained to somewhat excessively drained. A dense
subsurface soil layer, low in organic matter and slowly permeable, called a
fragipan, is often encountered in these soils. Fragipan may seriously impede
drainage and result in localized elevation (perching) of the groundwater table.
Shallowness of soil to bedrock or a fragipan, as well as numerous rock outcrops,
are the main limitations for farm and nonfarm uses (MPI, 1978a).
Soils that have been developed in glacial lake sediments occur quite exten-
sively on lake plains and valleys within the upper Hudson River Basin. These
deep soils, found on slopes ranging from nearly level or depressional to very
3-3
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steep, are classified as somewhat poorly drained to well drained. The wetness of
these clayey and silty deposits increases with depth; water contents as high as
60 to 70 percent have been reported (U.S. Department of Agriculture, Soil Con-
servation Service, [USSCS] 1975). These clayey and silty deposits are highly
susceptible to frost action and their sticky and plastic character makes them
difficult to work when wet.
The soils formed on plains, terraces, and glacial outwash deposits in the
valleys are deep, and somewhat excessively drained, and moderately coarse tex-
tured. Many of these soils are underlain by lenses of silt and clay that impede
their drainage. Droughtiness and the large number of coarse fragments are the
main limitations for farm uses.
Soils that have formed in recent alluvium on floodplains are usually deep,
medium textured (high in silt and very fine sand), and characterized by drainage
classes ranging from very poorly to well drained. These soils are all subject to
annual or more frequent periods of overflow, except along the Hudson River where
the flow is regulated. The water tables in these soils fluctuate and are deter-
mined to a large extent by the water level of adjoining streams. Flooding is
the main limiting factor for use of these soils.
Ib. Containment Site Geology
The following is a brief discussion of the bedrock, surficial geology, and
soils at the containment site. For more detailed discussions of field investi-
gations and environmental conditions at the containment site, the reader is
referred to MPI (1978b, 1980a, and 1980b).
Bedrock Geology
The bedrock that underlies the site and outcrops adjacent to the site is
part of the Snake Hill Formation. This rock is a dark gray, fissile (capable of
being split along closely spaced parallel planes), unweathered, moderately
jointed to broken, calcareous shale. There are a number of springs discharging
along the slopes and at the base of the rock outcrop south of the site. Depth to
3-4
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bedrock varies greatly at the site, from just below the ground surface in the
southeast and southwest corners to approximately 23 m (75 ft) below ground
surface in the northeast corner (MPI, 1980a).
Surficial Geology
The unconsolidated material overlying the bedrock at the containment site
consists of fine-grained sediments deposited in glacial Lake Coveville. The
clays are typically varved (layered) and were deposited during the retreat of the
Wisconsin Age glacier, approximately 13,000 years ago.
The varved clay begins between 89 to 167 cm (35 to 66 in) from the ground
surface and extends to a depth of 10 m (30 ft). The varves are a result of
seasonal sedimentation and consist of alternating laminae (thin layers) of dark
grayish-brown clay (from 0.5 to 3.8 cm [0.2 to 1.5 in] thick) and silty material
(less than 0.2 to 2.5 cm [0.1 to 1.0 in] thick). Occasionally, lenses of very
fine sand are found between the clay layers, but they do not appear to be con-
tinuous. Deposits of calcium carbonate are identifiable 61 to 91 cm (24 to
36 in) below the surface. The carbonate usually occurs in discontinuous vertical
seams, but at a few locations pockets of carbonate exist that are 8 to 10 cm (3
to 4 in) thick. The pockets of carbonate (lime) are generally found 1.2 to 1.5 m
(4 to 5 ft) below the surface and contain irregularly shaped carbonate nodules
that are 0.63 to 2.5 cm (0.25 to 1.0 in) in diameter. The major clay minerals
present are illite, montmorillonite, chlorite, and vermiculite with some trace
kaolinite and smectite (MPI, 1980a).
Analysis performed on the borings by the engineering firm of Muser, Rut-
ledge, Johnston, and Desimore (MRJD) (Richards, MRJD, April 22, 1980) indicates
that the unconsolidated material overlying the bedrock is variable in thickness.
In the northern and central parts of the containment site, the thickness of the
clay material ranges from 10 to 23 m (35 to 75 ft). Along the southern portion
of the site, bedrock is closer to the surface and the thickness of the clay
varies from 0.6 to 12 m (2 to 40 ft). In the south central portion of the site,
the bedrock outcrops and the overlying clay thins significantly. The actual
containment facility will not extend to this portion of the site (MPI, 1980b).
3-5
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The clay material at the site may be divided into two basic types. The
upper layer, identified by MRJD as stratum C , is basically a stiff, brown to
graybrown clay, varved with trace layers and pockets of silt to clayey silt with
occasional fine sand seams. The natural water content for this material ranges
from 29 to 38 percent of dry weight. Below this stratum is C , a softer clayey
material with an average water content that varies between 33 and 45 percent of
dry weight. Because C. material has a higher water content and is softer, CL
material is more suitable for use in the construction of containment dikes and
the clay cover (MPI, 1980a).
Laboratory and field tests were performed on the unconsolidated material to
determine the engineering, physical, and hydrologic characteristics of the
material. Tests of the permeability of the lake bed material indicate a range
from 2.5 x 10~7 to 5.88 x 10~6 cm/sec (8.2 x 10~9 to 1.92 x 10~7 ft/sec). New
York State regulations on hazardous waste deposits require a clay seal at the
site having a hydraulic conductivity of not greater than 1 x 10 cm/sec (3.3
x 10 ft/sec) and EPA requires an overall in-place permeability of not greater
-7 -9
than 1 x 10 cm/sec (3.3 x 10 ft/sec). Physical analysis of the varved clay
indicates that 90 percent of the particle sizes are finer than No. 200 sieve
size. An Atterberg Limit Test run on both pure clay samples and clay varved
with silt indicated that the Liquid Limit is greater than 30 and a Plastic Index
greater than 15 (MPI, 1980a).
Soils
The predominant soil type found in approximately 53 percent of the contain-
ment site is the Kingsbury silty clay. Other similar soils found at the site
are the Covington silty clay loam and the Vergennes silty clay loam, which
account for about 20 and 21 percent of the area, respectively. A minor portion
of the site (6 percent) is Nassau shaly silt loam, a shallow, medium-textured
soil that formed in glacial deposits. Properties of these soils are presented in
Table 3-1. The Kingsbury soil occupies the nearly level portions of the site,
while the Vergennes soils have formed on the more sloping sections. Covington
soils are found along drainways and at the base of slopes (USSCS, 1975).
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Table 3-1
Characteristics of Soils within the Containment Site
Soil
Series
Kingsbury
silty clay
Vergennes
silty clay
loam
Covington
silty clay
loam
Nassau
shaly silt
loam
Area
Occupied
Percent of
Total
53
21
20
6
Dei
Bedrock
(m) (ft)
>!..! >3.5
>1.1 >3.5
>1 . 1 >3 . 5
0.3- 1-3.5
1.1
ith to
Seasonal High
Water Table
(m) (ft)
0-0.6 0-2.0
0-0.6 0-2.0
0-0.6 0-2.0
0.5- 1.5-
1.1 3.5
Drainage
Somewhat
poorly to
poorly
Moderately
well
Somewh at
poorly to
poorly
Somewhat ex-
cessively
well to well
Land Use
Capability
Severe limita-
tions due
to periodic
standing water
Very severe
limitations
due to risk
of erosion
Very severe
limitations
due to per-
iodic stand-
ing water
Very severe
limitations
due to risk
of erosion
Agricultural
Suitability
Soils have
severe limita-
tions that re-
duce choice of
plants
Majority have
severe limita-
tions that re-
duce choice of
plants
Soils have se-
vere limita-
tions that re-
duce choice of
plants
Soils have se-
vere limita-
tions that re-
duce choice of
plants
Note: 1. These depths are for typical soils. It may vary significantly depending on the location.
Source: MPI, 1980a.
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The agricultural potential for Site 10 is limited. The majority of soils
fall within agricultural suitability Classes III and IV. These are defined as
having severe agricultural limitations, primarily due to excessive wetness and
slow permeability, that reduce the choice of plants and/or require special
conservation practices. Kingsbury soils are estimated to yield 27 to 36 metric
tons (t)/ha (12 to 16 short tons [tn]/a) per year of corn for silage, or 5.6 to
9.0 t/ha (2.5 to 4.0 tn/a) per year of forage mixture. Vergennes soils are
estimated to yield 27 to 40 t/ha (12 to 18 tn/a) per year of corn for silage,
4,350 to 6,960 liters (l)/ha (50 to 80 bushels [bu]/a) per year of corn for
grain, or 5.6 to 11.2 t/ha (2.5 to 5.0 tn/a) per year of forage mixture. Coving-
ton soils are estimated to yield 4.5 to 7.8 t/ha (2.0 to 3.5 tn/a) per year
of forage mixture. Nassau soils are estimated to yield 4.5 to 6.7 t/ha (2.0 to
3.0 tn/a) per year of forage mixture (Newton, March 28, 1981). Therefore, on the
proposed containment site the potential yields are estimated to be 20 to 27 t/ha
(9 to 12 tn/a) per year of corn for silage, 870 to 1,390 1/ha (10 to 16 bu/a) per
year) of corn for grain, or 5.4 to 9.0 t/ha (2.4 to 4.0 tn/a) of forage mixture.
At present the proposed containment site is not active farmland. The current
property owner is neither a farmer nor a resident of the area (Newton, March 28,
1981).
Ic. River Bed Materials in Upper Hudson River
The sedimentary deposits within the upper Hudson River in the area between
Glens Falls and Troy are characterized by geographically and temporally inter-
mittent distributions, caused by varying hydraulic regimes and sediment sources.
In areas of moderate velocity, bottom materials consist primarily of sands and
gravels in combination with concentrations of coarse-grained organic debris
including wood chips, sawdust, and lath. Within low velocity backwater areas,
sediments become progressively finer as the coarser materials are replaced by
silts and clays (LMS, 1978). Sediments with a grain size ranging from medium
to very fine sand can be eroded at the lowest velocities and, therefore, tend to
accumulate in the more protected areas. Both clays and gravel require much
higher velocities to be eroded. The clays are held in place by cohesive forces,
while the gravel is held in place by its weight (Vanoni, 1977).
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Numerous sampling programs of the upper Hudson River bed material have been
carried out as part of this study. The most extensive program was carried out
by Normandeau Associates from 1976 to 1977. Cores of river bed deposits were
obtained from Lock 7 at the Troy Dam and were analyzed for PCB concentrations,
sediment grain-size distribution, sediment/PCB relationships, and distribution of
PCBs within the river channel. Detailed discussions of the results of this and
other river surveys can be found in Tofflemire (1976), Tofflemire and others
(1979), Tofflemire and Quinn (1979), and MPI (1978a, 1980c). The following is a
brief summary of the findings.
The majority of the Thompson Island Pool samples had average grain sizes
that ranged from fine to very fine sand. Overall, the median grain size of the
hot spots fell within the very fine sand range. Approximately 21 percent of the
samples had average grain sizes greater than 2 millimeters (mm) (0.08 in), and a
large portion of the gravel-sized material consisted of wood chips.
Samples obtained along the length of the river were extremely variable, but
indications are that finer textured materials were more common closer to the
shoreline and in slack water deposits. In general, the Thompson Island Pool
deposits had a coarser texture than those found in the downstream pools. Average
organic and clay contents of bed deposits are presented in Table 3-2.
Organic materials within the bed deposits ranged from colloidal size humus
to wood fragments several feet in length. Organic matter has been shown to
adsorb PCBs from waters, thereby largely affecting PCB concentration and distri-
bution within the bed deposits.
Total volatile solids within the deposits ranged from 0.6 to 92.7 percent by
weight in the Thompson Island Pool and from 0 to 93.1 percent by weight south of
the pool. The average content of volatiles for the total study reach was approxi-
mately 7.0 percent by weight. The high percentages of volatile solids within the
deposits are due to wood fragments. Most of the volatile solids within the
material were associated with the gravel-sized fraction (MPI, 1978a).
PCB values tend to be high in coarse sand-sized particles, low in sand-sized
particles, and high again in the silt- and clav-sized particles. The coarse
3-9
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Table 3-2
Bed Deposit Properties
Pool
Thompson I
Lock 5
Lock 4
Lock 3
Lock 2
Lock 1
Total Reach
Percent
Clay
5.82
7.53
4.01
7.27
3.96
0.74
5.34
Percent
Volatile
Solids
(by weight)
7.5
11.8
4.36
10.07
3.76
2.23
6.96
Number
of
Samples
211
118
293
36
9
4
671
Source: MPI, 1978a.
3-10
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fraction contained a significant higher percentage of volatile solids (largely
wood chips), thus accounting for the high PCB content. PCBs also adsorb to clays
and fine silts (Tofflemire arid others, 1979; Tofflemire and Quinn, 1979).
The greatest quantities of PCBs are located immediately downstream from the
former discharge points in the remnant deposits and in the Thompson Island Pool.
Estimates of PCBs in the remnant deposits range from 29,000 kg (64,000 Ib)
(Tofflemire and others, 1979) to 63,500 kg (140,000 Ib) (MPI, 1978a), and in the
Thompson Island Pool from 53,500 kg (118,000 Ib) to 60,600 kg (133,700 Ib) (MPI,
1978a). The entire upper Hudson River, including the remnant deposits, is
believed to contain between 148,800 to 178,700 kg (328,200 to 394,000 Ib) of
PCBs.
The average level of PCBs exceeds 50 ug/g (ppm) in the Thompson Island Pool
and Lock 5 pool, but is lower in the remaining pools (MPI, 1978a). Concen-
trations generally decrease with distance downstream, although the Lock 4 pool
levels are low in comparison with those of the Lock 2 and 3 pools.
PCB levels in the center of the river and along the eroding bank are typi-
cally in the range of 5 to 20 ug/g, (ppm) while levels along the depositional
. . c
shore may range from 50 to 1,000 ug/g (ppm) in fine grained sediments. Stati-
stical analyses in the Thompson Island Pool and Lock 5 and 6 pools showed sign-
ificantly higher PCB levels along near-shore areas of the river, in comparison to
the middle third of the river. The differences among the Lock 1, 2, and Troy Dam
pools were not significant (Tofflemire and Quinn, 1979).
NYSDEC has prepared a summary tabulation of average PCB concentration with
depth of sediment core (Tofflemire and Quinn, 1979). The cores were taken
principally in the soft near-shore sediments. Cores registering less than 6 ug/g
(ppm) PCBs were not included. Above Lock 7 and in the Thompson Island Pool, peak
PCB levels of approximately 130 ug/g (ppm) were generally found at depths of 30
to 45 cm (12 to 18 in). Further downriver from the Lock 6 pool to the Troy Dam,
the PCB peak typically occurred at between 8 to 30 cm (3 and 12 in) deep. The
peak PCB strata averaged about 150 ug/g (ppm) in the Lock 5 and 6 pools, and
decreased to approximately 50 ug/g (ppm) in the remaining downstream pools
(Tofflemire and Quinn, 1979).
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' Sediment samples taken in a variety of locations in the upper Hudson River
show elevated levels of chromium, lead, and zinc in addition to PCB. Sediments
from behind the original Fort Edward Dam that were examined in 1970 contained
lead and zinc in very high levels, up to 3,630 and 2,950 ug/g (ppm), respec-
tively (Clarkson and Clough, 1970). Limited samples taken in the remnant de-
posits following the removal of the dam in 1973 showed very high levels of lead,
up to 5,600 ug/g (ppm) (MPI, 1978b). Elevated sediment levels of chromium,
lead, and zinc were found at the Thompson Island Pool (Tofflemire, 1976) and at
the confluence with the Moses Kill (GE, 1977). Representative grab samples
taken by NYSDOH throughout the upper Hudson River showed the following mean
values: chromium, 705 ug/g (ppm); lead, 387 ug/g (ppm); and zinc, 217 ug/g
(ppm) (Tofflemire and Quinn, 1979).
Statistical analysis indicates that of the metals sampled, the distribution
of lead most closely approximates the distribution of PCBs. (The correlation
coefficient of log lead versus log PCBs is 0.609.) This observation is based on
grab samples taken to depth of six inches, which are, therefore, likely to
consist of recently deposited sediments. The correlation suggests that lead
levels should be closely monitored during any remedial dredging (MPI, 1980d).
Id. River Bed Materials in Lower Hudson River
The estuarine portion of the river below the Federal Dam is estimated to
contain 75,700 kg (167,000 Ib) of PCBs (Bopp, 1979; Bopp and others, 1981). The
following depositional areas in the lower Hudson River have higher concen-
trations of PCBs: Albany turning basins (River Mile 109.5), Kingston area (River
Mile 85 to 93), Haverstraw Bay and the Tappan Zee, New York Harbor, and other
coves and bays. Among these areas, New York Harbor has the greatest mass of
PCBs, 23,100 kg (51,000 Ib), at an average concentration of 3 ug/g (ppm) (MPI,
1980d). Bopp (1979) estimates that 70 to 75 percent of the PCBs in New York
Harbor originated from discharges to the upper Hudson River.
2. WATER RESOURCES
.2a. Surface Water
Hudson River Basin
The Hudson River Basin covers 34,615 square kilometers (sq km) (13,365
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square miles [sq mi]), 27 percent of New York State. From the Hudson-Sacandaga
River junction south to Fort Edward, there is a series of seven dams and three
natural waterfalls that are used to generate hydroelectric power. From south of
Fort Edward to the Federal Dam at Troy, the Hudson River is regulated by a series
of eight dams. In addition to these dams, there are seven locks that are part of
the Champlain Canal System. The Hudson River from Albany to New York Harbor is a
tidal estuary (MPI, 1980d).
The drainage area of the Hudson River varies from 7,299 sq km (2,818 sq mi)
at Fort Edward to 20,953 sq km (8,090 sq mi) at the Federal Dam at Troy. To
maintain navigation and power generation, flows are regulated to a minimum of 85
cu m/sec (3,000 cfs). The minimum depth of 3.6 m (12 ft) is maintained for
navigation.
Several reservoirs above Glens Falls affect flow levels in the upper Hudson
River. The Sacandaga Reservoir is a 940 million cu m (247,650 million gal)
impoundment on the Sacandaga River, which joins the Hudson River at Hadley.
Flows from the reservoir are regulated during low flow to maintain navigation,
water quality, and power generation downstream. Flows from the reservoir are
regulated to control flooding during high flows. Water is released from this
reservoir to maintain a minimum of 85 cu m/s (3,000 cfs) at Spier Falls (MPI,
1980d). Other reservoirs that affect flows in the upper Hudson River are Indian
Lake, Piseco Lake, Spier Falls Reservoir, and Sherman Island Reservoir.
Low flows are generally observed between July and October of each year and
have been recorded at 14 cu m/sec (500 cfs). April and May are annual high flow
periods when rates over 280 cu m/sec (10,000 cfs) are common, and a flow of 1,113
cu m/sec (39,319 cfs) was recorded on April 2, 1976, during the 100-year flood.
Water Quality
New York State water quality classifications and standards are listed in
Table E-l (Appendix E). Classifications for the upper Hudson River vary from "A"
to "D" and are based on the intended "best use" for these waters. Classification
of the river, as reported by MPI (1978a), is as follows:
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From Lock 7 downstream to the mouth of the Snook Kill 3.7 km (2.3
mi) the waters are classified 'D': suitable for secondary contact
recreation but not for the propagation of fish. From the Snook
Kill to Fort Miller 9.0 km (5.6 mi) the classification changes to
'C': intended as suitable for fishing and other uses except
water supply and contact recreation. The classification reverts
to 'D' downstream to the mouth of the Batten Kill (6.1 km) (3.8
mi), then back to 'B' along the 25.7-km-(16-mi) section south to
Lock 3. 'B' waters are intended as suitable for contact re-
creation and other uses except water supply. The classification
is reduced to 'D' betwen Locks 2 and 3, but is upgraded to 'A'
below Lock 2, a classification that does not necessarily reflect
improved water quality as much as the fact that this section is
used as a public water supply for the Village of Waterford.
Water quality data for the Hudson River are collected by NYSDEC, USGS, and
NYSDOH. These data are presented in Table E-2 (Appendix E). The data show that,
with the exception of mercury, lead, hydrocarbons, and phosphorus, all parameters
measured meet state and federal standards. The maximum level for lead that is
recommended by EPA is 12 ug/1 (ppb) in soft waters.
Point and Non-Point Sources
Glens Falls, Fort Edward, Fort Miller, and Mechanicville discharge munici-
pal and industrial wastes into the Hudson River, causing adverse effects on water
quality. The water quality downstream from Mechanicville improves because of
dilution and the biological and chemical breakdown of pollutants (MPI, 1978a).
Non-point source (NFS) runoff results primarily from agriculture and can
cause increased nutrient levels, turbidity, and erosion. Levels of NFS have not
been quantified (MPI, 1978b).
2b. Groundwater
Regional Groundwater
Two main types of groundwater aquifiers occur in the study area: Ordovician-
aged consolidated rocks, and Pleistocene-aged unconsolidated sediments. The
consolidated rocks generally have low effective primary porosities. However, in
many areas, the presence of joints, fractures, and fault zones has significantly
increased the permeability of formations. Yields reported for 192 wells drawing
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from the shale aquifer in Washington and Saratoga Counties ranged from 2.0 to
300 liters per minute (1pm) (0.5 to 80 gallons per minute [gpm]) and averaged
about 34 1pm (9 gpm). Water from shale wells is generally hard and may contain
hydrogen sulfide (MPI, 1978a).
The unconsolidated deposits yield water of varying quality and at differing
rates. Because of its low porosity, glacial till yields water very slowly. The
estimated average yield of these deposits is from 4 to 8 1pm (1 to 2 gpm). The
more productive wells derive water largely from thin sand lenses in the till.
Glacial outwash deposits have high permeabilities. These stratified sands and
gravels have average yields of 19 to 38 1pm (5 to 10 gpm). Deltas are the most
productive water-bearing glacial outwash formations. Lacustrine deposits of clay
and silt yield water very slowly and seldom in usable quantities. The alluvial
deposits found in the study area are not coarse enough or thick enough to be
important as sources of groundwater.
Containment Site Groundwater
It is difficult to define a true water table at the containment site because
of the variable nature of the lake bed sediments and the extremely low permea-
bility of the clays. The slowly permeable clays retard groundwater flow to
the point that test pits dug through the silty layers to depths between 1.6 and
2.6 m (5 and 8 ft) accumulated water so slowly that a stable level could not be
determined (MPI, 1980a). Water levels were monitored in five piezometers in-
stalled across the site and, after several days of monitoring, stable water
levels were reached. These water levels varied from 0.9 to 1.2 m (3.0 to 4.1 ft)
below the ground surface. In one boring that penetrated the bedrock, artesian
conditions were encountered, but the full height was not measured (MPI, 1980a).
The thin lenses of fine sand contain pockets of more mobile groundwater.
However, the evidence obtained from systematic boring across the site indicates
that the extent these lenses is limited and they are not hydraulically connected
to each other or to the Hudson or Dead Rivers. Therefore, the groundwater is
immobilized within these lenses and, if contaminated, would remain in the same
location (MPI, 1980b).
The existence of a water table less than 3 m (10 ft) from the bottom
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of the containment facility would prevent New York State regulatory bodies from
approving the site as a secure landfill facility. A waiver would be required for
construction of the facility.
The site does not recharge any aquifers in the area. Because of the high
clay content of the soils and underlying unconsolidated material, most precipi-
tation falling on the site flows into the Hudson and Dead Rivers as surface
runoff. The presence of a small wet area in the south part of the site also
indicates the poor infiltration capacities of these soils.
Wells in the area of the containment site are used largely for domestic
supplies and are located predominantly along Route 4 near the river. These wells
vary from 8 to 58 m (25 to 190 ft) in depth and produce up to 76 1pm (20 gpm) of
potable water. The formation used is the Snake Hill Shale and the amount of
water produced depends on the extent of interconnecting fractures. The formation
is recharged where it outcrops approximately 2.5 km (1.5 mi) to the east of the
containment site. It is also recharged to a lesser extent by induced infil-
trations from the Hudson River. The formation water has a high iron sulfide
content and, in some cases, is not potable.
2c. Water Supply
A number of communities obtain drinking water from the Hudson River, includ-
ing the Village of Waterford, the Port Ewen Water District, the Village of
Rhinebeck, the City of Poughkeepsie, and the Highland Water District (MPI,
1980d). In addition, several municipalities and numerous private individuals
obtain water from wells adjacent to the river. Stillwater, for example, operates
four wells and Green Island draws water from infiltration galleries located on an
island in the upper Hudson River. Some homes along the Hudson River also use the
river as a supplemental water supply for watering lawns and gardens (MPI, 1980d).
In addition, a water intake exists at Chelsea, which may be used to augment
water supplies for New York City during drought conditions.
Hudson River water is analyzed by the USGS at five stations on the upper
reaches: Glens Falls (above the GE plant), Rogers Island, Schuylerville, Still-
water, and Waterford (Tofflemire, NYSDEC, 1980). Although the Glens Falls PCB
3-16
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levels are usually below the detection limit of 0.1 ug/1 (ppb), there are data
for Schuylerville and Stillwater for the three water years beginning in October,
1976. The average PCB concentrations for these years were: 0.687 ug/1 (ppb) in
1977, 0.568 ug/1 (ppb) in 1978, and 0.657 ug/1 (ppb) in 1979. Higher levels have
been reported for the 1974 to 1975 period at Rogers Island 1.5 ug/1 (ppb), and
levels as high as 3 ug/1 (ppb) were recorded in the Hudson River prior to elimi-
nation of GE discharges in 1976.
PCBs in Hudson River drinking waters can be reduced by 40 to 80 percent
through treatment (Cranston, City of Poughkeepsie, August 25, 1977). If standard
water treatment measures (alum coagulation, settling, aeration, sand filtration,
and chlorination) are used, levels of PCBs in finished water can be reduced from
the present approximate level of 0.65 ug/1 (ppb) to about 0.20 ug/1 (ppb).
There was no significant difference in the amount of PCBs in the water for the
three-year period between 1977 and 1979. These levels probably represent back-
ground levels for residents using the Hudson River, and possibly also wells and
infiltration galleries near the river, for drinking water. Residents using this
water may assimilate approximately 0.3-1.3 ug/day at an average water consumption
rate of 2 Ipd (0.5 gpd). Monitoring of Hudson River water at Poughkeepsie and
Waterford by the USGS indicated PCB levels below the maximum level of 1.0 ug/1
(ppb) established by NYSDOH and below the 0.16 ug/1 (ppb) level calculated to
represent a lifetime cancer risk of one in one million (MPI, 1980d).
NYSDEC data indicate that primary and secondary federal and state drinking
water standards are presently being met in finished water at the five water
supply intakes along the Hudson River (Appendix E). In addition, the 1 ug/1
(ppb) short-term exposure standard for PCBs developed by the NYSDOH is also
being met. However, it should be noted that during high flow periods, or 10
percent of the time, the 1 ug/1 (ppb) standard for PCBs in finished water may be
exceeded at some of the treatment facilities (Figure 2-1).
3. AQUATIC ECOLOGY
- The lower Hudson River south of the Troy Dam is an estuarine ecosystem.
The river's free connection to the ocean, the mixing of ocean salt water with
freshwater from the land, and the resulting salinity gradient below Poughkeepsie
are the main factors affecting the flora and fauna of the lower Hudson River.
3-17
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Extensive development of the shoreline of New York City and cities to the north,
as well as the intense use of the river for navigation and industry, have also
substantially affected the ecosystem. The estuarine ecosystem of the lower
Hudson River is described in An Atlas of the Biologic Resources of the Hudson
Estuary (BTI, 1977). A complete listing of the aquatic flora and fauna of the
lower and upper Hudson River is given in Hudson River Fish and Wildlife [NYSDEC
and USFWS, 1978]. (These reports are on file at the five designated depositories
as a supporting document to this draft NEPA EIS.)
Above the Troy Dam, the Hudson River is not influenced by the inflow of
ocean waters and is a freshwater river ecosystem with corresponding freshwater
flora and fauna. The ecology of much of the upper Hudson River between Troy and
Hudson Falls has been substantially altered by industrial utilization.
3a. Flora
Aquatic vegetation is abundant in tidal shallows and marshes of the lower
Hudson River. In the lower estuary, vegetation tolerant of brackish waters
predominates, and freshwater vegetation exists in up-river areas. Submerged
aquatic vegetation in the Hudson River includes pondweed, water celery, and water
milfoils. Vegetation in freshwater marshes is comprised of cattails, reeds,
purple loosestrife, swamp rosemallow, ferns, spike grass, cordgrass, arrow
arum, and pickerel weed. Wooded wetlands exist on portions of the river bank and
on islands in the river. A complete description of the vegetation of the lower
Hudson River is given by the BTI (1977). Typical freshwater wetland species are
described by Rawinski and others (1979).
The wetland and submerged vegetation provides cover and substrate for a wide
variety of Crustacea, snails, insects, and other fauna. It is also.utilized as
food for ducks, geese, other waterfowl, and muskrats. Detrital material derived
from the vegetation is consumed by filter feeders such as zooplankton, benthic
invertebrates, and menhaden (BTI, 1977).
" The Hudson River also contains a diverse phytoplankton community, with
marine species dominant in the lower estuary. Diatoms, green algae, dinoflagel-
3-18
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lates, and blue-green algae comprise most of the phytoplankton population (BTI,
1977; Hydroscience, 1979).
3b. Wetlands and PCB Hot Spots
In the upper Hudson River, 8 of the 40 PCB hot spots that have been identi-
fied by NYSDEC contain wetlands. A brief description of each is given in Table
3-3. Wetlands are not common in the upper Hudson River; they tend to be located
in quiescent, depositional areas behind dams or along the margins of islands and
the river bank (MPI, 1980d). Because of this, they also tend to be sites of PCB
deposition. These wetlands support extensive marsh vegetation and are locally
significant habitats for wildlife, especially -nesting and breeding waterfowl
(MPI, 1980d). The principal species encountered are black duck, mallard, wood
duck, golden eye, scaup, green-winged teal, blue-winged teal, and merganser (MPI,
1978a).
NYSDEC has designated the hot spot wetlands, that are particularly valuable
as wildlife habitats (Koechlein, NSYDEC, June 5, 1980). Hot spot 35 contains a
diverse wetland that is extensively utilized by waterfowl. The wetlands at hot
spot 40 and between hot spot 39 and Lock 2 are also especially valuable. These
wetlands should be restored following any remedial action involving the hot
spots.
The preliminary results of a study of PCB levels in wetland vegetation are
available (Buckley, BTI, February 6, 1981). These results indicate that PCB
levels in the roots and rhizomes of the marsh plants Pontederia, Leseria, and
burr reed (Sparganium eurycarpum) are generally comparable to PCB levels in marsh
soils. In the hot spot wetlands, PCB levels in plant roots are high because of
the high PCB levels in the soil. Plant portions that are submerged obtain their
PCB content from PCBs in the water column. Similarly, PCB levels in plant
portions extending above the water derive their PCB content from airborne PCB.
Evidence indicates that there is little upward translocation of PCB from roots to
leaves in these marsh plants (Buckley, BTI, February 6, 1981). If this is the
case-, PCB uptake from the soil by these three plant species may not be a signifi-
cant pathway for release of the contaminant from hot spot deposits.
3-19
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Table 3-3
Hot Spots and Wetlands
Hot Spot
1-7
8
9-12
13
14
15-17
18
19,20
21-24
25
26,27
Mean PCB
Concentration
ug/g (ppm)
39-81
99
28-78
89
279
103-380
94
83-249
75-143
100
47-53
Contaminated
Vo lume
cu m (cu yd)
98,150 (128,350)
82,850 (108,350)
23,400 (30,600)
1,550 (2,050)
55,150 (72,150)
46,200 (60,450)
11,450 (14,950)
5,950 (7,750)
10,650 (13,950)
10,650 (13,900)
7,050 (9,200)
Comments
No wetlands.
Shallow water on east side of
islands includes limited wetlands.
Area judged not to present major
conflict. Should additional
sampling indicate localized, less
contaminated areas, these should
remain undisturbed. Many
overhanging and fallen trees and
shallowness will present some
hindrance to dredging.
No wetlands.
Southern limit of hot spot is at
access road berm, major marsh lies
to the south. No conflict with
wetlands.
No emergent, some floating and
submerged species. Not a wetland.
No wetlands.
Diverse 9 m (30 ft) wide band of
marshland present. Conflict
exists.
No significant wetlands.
No significant wetlands.
Wetland is present. Southern
portion of Galusha Island, no
conflict. Northern portion
contains diverse marsh community
and provides valuable waterfowl
habitat. Significant conflict.
No significant wetlands.
3-20
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Table 3-3 (Continued)
Hot Spot
28
29-34
35
36
37
38
39
40
Mean PCB
Concentration
ug/g (ppm)
109
51-516
105
51
116
501
161
62
Contaminated
Volume
cu m (cu yd)
36,350 (47,550)
49,450 (67,700)
8,700 (11,350)
42,750 (55,900)
43,900 (57,400)
11,300 (14,750)
10,050 (13,150)
26,300 (34,400)
Comments
A broad expanse of emergent sedge,
pickerel weed, rushes, rice cut
grass; offers excellent duck brood
habitat. Significant conflict
exists.
No wetlands.
Valuable wetland used by waterfowl,
herons, other shore birds. Diverse
mixture of vegetation types.
Distribution of PCB in wetland
should be verified. Significant
conflict exists.
No wetlands.
Large area of water lilies and
water chestnut, used by diving
ducks1 during migration. No
major conflict.
No wetlands.
5 ha (13 a) wetland below hot
spot, probably no conflict exists.
Sampling is meager, marsh
discontinuous. Additional sampling
needed.
Valuable diverse wetland communi-
ties, conflict exists. Recent
sampling indicates the area
may not be "hot."
Note: 1. Assumed value, no samples in this area at this time.
Source: a. MPI, 1980d.
3-21
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Water celery (Vallisneria americana Michx.), a submerged aquatic plant
sampled from the wetland at hot spot 28, contained high levels of PCB in plant
roots and tops. PCB levels in plant tops, roots, and river sediments were 18.94,
51.8, and 41.1 ug/g (ppm), respectively (Buckley, BTI, February 6, 1981). PCBs
incorporated into the plant can enter the ecosystem because the plant may
serve as food for aquatic birds, especially ducks and geese. Additional PCBs
would be absorbed by the organic detritus that is produced when the leaves die,
break off, and start to decompose. Upon complete decomposition of the plant
parts, the PCBs would be released again into the sediments and water column. A
small portion of the detritus would enter the food chain (Buckley, BTI, March 12,
1981).
Loss of PCBs from wetland hot spots may occur from volatilization from
marsh soils. However, these hot spots also contain large amounts of organic
materials, which tend to adsorb PCB and inhibit the release of the contaminant to
the atmosphere (MPI, 1980d).
Scouring of wetlands during periods of high river flow can cause resus-
pension of PCB-laden sediments and their release to the river system. Wetlands
tend to be less subject to scouring than other river areas because the vegetative
cover tends to hold sediments in place (MPI, 1980d).
Ice that forms on the river during the winter months may also be an important
mechanism for release of PCB-contaminated sediments from wetlands. Field studies
along the St. Lawrence River have indicated that mats of wetland sediment that
are frozen to the underside of ice can be carried away when water levels rise
during the spring thaw. In addition, ice floes can scour wetlands and abrade
river banks as ice is moved downstream during the spring melt (Marshall, February
26, 1981). The degree to which ice scouring of wetlands occurs on the Hudson
River is not known.
The effect of the high PCB levels on wetland vegetation in the hot spots is
also unknown. There is limited evidence that submerged aquatic plants are
sensitive to elevated PCB levels. Photosynthetic activity in the aquatic plant
3-22
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Spirodela oligorrhiza has been shown to be greatly reduced by PCB concentrations
of 5 ug/g (ppm) in the ambient water (Mahanty and Fineran, 1976).
3c. Fauna
Zooplankton, including copepods, water fleas, larval snails, and other
mollusks, are found throughout the Hudson River but are most abundant in the
brackish waters of the lower estuary. Zooplankton are important food sources of
certain fish, particularly young striped bass, young white perch, and anchovies
(BTI, 1977).
Snails are the most abundant mollusks in the Hudson River, but clams and
oysters are found in the lower estuary. Crustaceans are represented mainly by
copepods and amphipods. Blue crab (an important recreational species) is found
in the lower estuary (BTI, 1977). Turtles, frogs, and other reptiles and amphib-
ians are present throughout the Hudson River system, especially in wetlands.
A large variety of fish inhabit the Hudson River and many are commercially
and recreationally important (Smith, 1977). A list of fish species recorded
in the Hudson River, along with brief descriptions of their origins and habitats,
is presented in Appendix F. The lower Hudson River serves as a spawning area for
several anadramous fish, including striped bass, American shad, and Atlantic
sturgeon. The broad shallow areas of Havertraw Bay are especially productive for
spawning and rearing. The lower Hudson River is the second most important
propagation area for striped bass on the east coast. Hudson River striped bass
comprise a significant portion of the striped bass fishery on the east coast,
which generally has a commercial and recreational value of $20,000,000 per year
(MPI, 1980d).
Other commercially valuable fish that inhabit the lower Hudson River in
their juvenile stages include bluefish, weakfish, and winter flounder. Bay
anchovies are abundant in brackish water, and the species is a major food source
for larger fish (BTI, 1977). The shortnose sturgeon, a species that is on the
federal list of rare and endangered species, also inhabits the lower Hudson
River. The species will be discussed in section 5 of this chapter.
3-23
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Freshwater fishes that inhabit the Hudson River include shiners, goldfish,
carp, white sucker, brown bullhead, white catfish, white perch, yellow perch,
blue gill, pumpkinseed, black crappie, darters, walleye, chain pickerel, northern
pike, largemouth bass, and smallmouth bass. The American eel is abundant
throughout much of the Hudson River (BTI, 1977; Smith, 1977).
Additional information on the aquatic ecosystem of the upper Hudson River is
given by MPI (1978a).
3d. Hudson River Fishery
In 1976, much of the Hudson River fishery was closed by NYSDEC because many
fish were found to have PCB levels that exceeded the FDA temporary tolerance
level of 5 ug/g (ppm). The NYSDEC regulations that have been enacted are:
Title 6 of the Official Compilation of Codes, Rules and Regulations of
the State of New York.
Section 12.19 Regulations for the taking of fish and American eel in
the Hudson River and their sale or offer for sale:
(a) All fishing and taking of American eel is prohibited in the
Hudson River, and its tributary waters upstream from the River to
the first falls or barrier impassable by fish, from Fort Edward
downstream to the Troy Dam.
(b) In the Hudson River, and its tributary waters upstream from the
river to the first falls or barrier impassable by fish, from the
Troy Dam downstream to the mouth of the river at the Battery, New
York City, until November 30, 1981, no person shall:
(1) Take or possess American eel.
(2) Fish commercially except for Atlantic sturgeon greater than
four feet in length, goldfish and American shad. For the
purposes of this subdivision, commercial fishing shall
include, but not be limited to, the possession, setting,
tending, operation and maintenance of nets or other devices
for which a license is required pursuant to Section 11-1503
of the Fish and Wildlife Law and the sale, offering for sale
or possession of fish taken in any of the foregoing nets or
devices.
(3) When commercial fishing, take or possess striped bass, or
fail to immediately return striped bass to the water.
(4) Set gill nets from December 1 through March 14.
3-24
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(c) The sale, or offer or exposure for sale, of any American eel or
any fish, except for Atlantic sturgeon greater than four (4) feet
in length, goldfish and American shad, taken in the Hudson River,
or its tributary waters upstream from the River to the first falls
or barrier impassable by fish, from Fort Edward downstream to the
mouth of the River at: the Battery, New York City, is prohibited.
In 1971, NYSDEC also issued an advisory against eating more than 230 g
(0.5 Ib) of fish per week from any New York State waters because of mercury
contamination. This advisory was subsequently extended because of PCBs, and
it remains in effect today (Sloan, NYSDEC, March 10, 1981).
Despite the regulations and advisory, illegal fishing, especially sport and
subsistence fishing, and consumption of contaminated Hudson River fish continues
(MPI, 1980d). Illegal commercial fishing of striped bass occurs in the lower
Hudson River because the fish has a relatively high market value. NYSDEC en-
forcement officials have intercepted sizeable quantities of Hudson striped bass
ready for shipment to markets in New York City (Sloan, NYSDEC, March 10, 1981;
Blumenthal, New York Times, April 3, 1981).
PCS Levels in Fish
When widescale testing for PCBs in fish began in 1977, it was found that PCB
contamination was extensive (MPI, 1980d). Uptake of PCBs by fish probably occurs
primarily by diffusion of contaminated water through gills, skin, and other
tissues. PCBs accumulate in fatty tissues and can be biomagnified through the
food chain. Possible biological pathways of PCB movement in the environment have
been discussed (O'Connors and others, 1978; Hydroscience, 1979; Armstrong and
Sloan, 1980; MPI, 1980d).
PCB levels in Hudson River fish were found to vary greatly according to
species. Studies done in 1978 by NYSDEC revealed that 93 percent of all fillets
from striped bass (a large predatory species) contained concentrations of PCBs
over 5 ug/g (ppm), with median and mean concentrations of 10 and 18 ug/g (ppm),
respectively. PCB levels in fish that are full-time residents of the Hudson
3-25
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River, such as the largemouth bass, were also very high. Resident fish such as
eels, catfish, goldfish, and carp were found to have especially high PCB levels
primarily because these species have high fat content. Minnows and anadramous
shad and herring had low PCB levels, generally much less than 5 iig/g (ppm). The
blue crab had low PCB levels (around 0.5 ug/g [ppm]) in its muscle tissue, but
the hepatapancreas had considerably higher levels (over 5 ug/g [ppm]) (Armstrong
and Sloan, 1980).
Analysis of fish sampled since 1977 has shown a substantial drop in PCB
levels in many species. PCB levels in American shad caught at Poughkeepsie, for
example, decreased by 40 percent from 1977 to 1978, and by 50 percent from 1978
to 1979 (Armstrong and Sloan, 1980; MPI, 1980d). The 1980 data also indicate a
decline in PCB levels in striped bass. The trend in striped bass has not been as
apparent because the striped bass population in the Hudson River is comprised of
fish that are full-time residents of the river and fish that move into the river
temporarily to spawn. The two groups have different degrees of PCB accumulation
(Armstrong and Sloan, 1980; Sloan, NYSDEC, March 10, 1981).
Various factors may have contributed to the initally high PCB levels found
when extensive testing began in 1977 and the decline since then:
In 1974, the Fort Edward Dam was removed, releasing PCBs to downstream
areas and creating high background PCB levels.
In 1976, a significant flood occurred, resuspending PCB-laden sediments
and making the contaminant more accessible to uptake by fish.
In 1977, active direct discharge of PCBs ended.
From 1977 to 1979, flows in the Hudson River were relatively low and no
major floods occurred, causing minimal release of PCBs from sediments.
The principal forms of PCBs discharged by GE into the Hudson River and
incorporated into fish flesh were Aroclor 1242 and Aroclor 1016, which
are lower chlorinated aroclors compared to Aroclor 1254. Lower chlori-
nated aroclors may be less stable and subject to slightly greater degra-
dation in the environment (Armstrong and Sloan, 1980; MPI, 1980d).
1980 Fisheries Data
NYSDEC continued its monitoring of PCB levels in Hudson River fish through
1980. These data indicate that the decline in PCB levels is continuing primarily
3-26
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because levels of Aroclor 1016 are declining. Levels of Aroclor 1254, however,
are declining only slowly, if ait all, in Hudson River fish. Sampling in 1981
should clarify this point (Sloan, NYSDEC, March 10, 1981).
The PCB data collected by NYSDEC in 1979 and 1980 are given in Appendix G.
For ten species, 1980 PCB levels were compared with levels found in the same
species since 1977, as shown in Table 3-4. Only levels in fish sampled from the
same river location were compared. No account was made fpr size or lipid content
of the fish in the comparison.
For the five species sampled from the lower Hudson River, PCB levels were
lower in 1980. Levels in lairgemouth bass, white perch, yellow perch, and
American eel have declined substantially in the past seven years. The mean PCB
level in American shad was approximately 1.5'ug/g (ppm) in 1980, slightly lower
than the level for the previous year.
For largemouth bass, yellow perch, brown bullhead, and goldfish sampled from
the upper Hudson River at Stillwater, PCB levels were substantially lower in 1980
than in 1977; For the two species for which data are available (brown bullhead
and pumpkinseed), there was no significant difference between PCB levels in 1979
and 1980.
Data on the most important commercial and recreational species of the
regions, the striped bass, were not included in the comparison because possible
sample bias has made data suspect. Data for striped bass caught near the Tappan
Zee Bridge are given in Table 3-5. PCB levels in striped bass have declined,
but the magnitude of the decline remains unconfirmed because of the unreali-
ability of the data (Sloan, NYSDEC, March 10, 1981).
Of the ten species from the lower Hudson River represented in the 1980 data,
four still have mean PCB levels above the FDA tolerance level of 5 ug/g (ppm);
these are white perch, eel, walleye, and striped bass. The highest PCB level
recorded in the 1980 data for the lower Hudson River was 52.70 ug/g (ppm) for an
eel from the vicinity of the Verrazano Narrows Bridge. For the five species
3-27
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Table 3-4
Means and Ranges of PCB Levels in
Hudson River Fish
A. Lower Hudson River
year
1977
1978
1979
1980
Year
1977
1978
1979
1980
Year
1977
1978
1979
1980
American Shad
Poughkeepsie
No.
Sampled
33
87
N
29
Total
PCB
(ppm)
3.77
2.25
N
1.42
Range
Min Max
(ppm) (ppm)
1.11
0.30
N
0.63
11.45
6.73
N
3.87
American Eel
Indian Point
No.
Sampled
N
35
N
6
Total
PCB
(ppm)
N
81.83
N
<8.61
Range
Min Max
(ppm) (ppm)
N
1.06
N
<1.99
N
263.10
N
22.41
White Perch
Troy
No.
Sampled
N
61
N
30
Total
PCB
(ppm)
N
100.46
N
16.71
Range
Min Max
(ppm) (ppm)
N.
6.18
N
2.60
N
372.00
N
46.17
American Shad
Tappan Zee Bridge
No.
Sampled
19
77
15
30
. Total
PCB
(ppm)
2.40
2.16
<1.37
<1.55
Range
Min Max
(ppm) (ppm)
0.70
0.30
<0.57
<0.52
8.45
9.36
2.51
3.94
Largemouth Bass
Catskill
No.
Sampled
N
61
N
30
Total
PCB
(ppm)
N
100.46
N
16.71
Range
Min Max
(ppm) (ppm)
N
6.18
N
2.60
N
372.00
N
46.17
Yellow Perch
Catskill
No.
Sampled
25
N
N
10
Total
PCB
(ppm)
4.91
N
N
<0.98
Range
Min Max
(ppm) (ppm)
0.84
N
N
<0.30
10.60
N
N
4.82
Note: 1. N = No data available.
2. ug/g = ppm
3-28
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Table 3-4 (Continued)
B. Upper Hudson River
Year
1977
1978
1979
1980
Year
'
1977
1978
1979
1980
Pumpkins eed
Stillwater
Total
No. PCB
Sampled (ppm)
N N
N N
64 19.91
75. 20.12
Range
Min Max
(ppm) (ppm)
N
N
15.63
14.80
N
N
25.43
29.48
Yellow Perch
Stillwater
Total
No. PCB
Sampled (ppm)
30 12.23
N N
N N
7 <0.84
Range
Min Max
(ppm) (ppm)
1.56
N
N
<0.33
42.69
N .
N
2.15
Largemouth Bass
Stillwater
No.
Sampled
11
17
N
26
Total
PCB
(ppm)
52.41
158.20
N
10.16
Range
Min Max
(ppm) (ppm)
6.22
20.53
N
1.67
140.84
305.50
N
66.78
Brown Bullhead
Stillwater
No.
Sampled
30
N
30
30
Total
PCB
(ppm)
109.57
N
<8.97
12.34
Goldfish
Stillwater
Year
1977
1978
1979
1980
No.
Sampled
10
24
N
30
Total
PCB
(ppm)
382.90
216.05
N
72.62
Range
Min Max
(ppm) (ppm)
736.29
58.00
N
11.47
79.69
658.30
N
267.61
Range
Min Max
(ppm)
35.46
N
<0.83
3.50
(ppm)
242.19
N
59.79
30.11
Note: 1. N = No data available.
2. ug/g = ppm
Source: Hydroscience, 1979; Armstrong and Sloan, 1980; NYSDEC, unpublished data.
3-29
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Table 3-5
PCB Trends for Striped Bass, Hudson River, 1973-80,
Tappan Zee Bridge
Date
1973a
1975a
1976a
1977a
1978a
1979a
1980b
1980b
No.
Fish
22
6
46
5
130
14
301
302
Mean Length
mm (in )
654 (26)
666 (26)
543 (21)
507 (20)
549 (22)
456 (18)
468 (18)
515 (21)
Total PCB
ug/g (ppm)
14. 753
11. 023
8.62
8.01
10.33
5.27
5.59
6.37
Ratio of
Aro 1016 to
Aro 1254
NA
NA
0.80
0.28
0.88
0.31
NA
NA
Notes: 1. Sampled 4-14-80
2. Sampled 5-8-80
3. Aroclor 1254 measured only
4. NA = Not available.
Sources: a. Armstrong and Sloan, 1980.
b. NYSDEC, unpublished data.
3-30
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sampled from the upper Hudson River, all but yellow perch had levels well above
5 ug/g (ppm). The highest levels were found in goldfish, with a mean PCB concen-
tration of 72.62 ug/g (ppm).
Effects of PCBs on Health of Fish
The effects of PCBs on the health of natural fish populations are not well
understood. Adverse effects may be greatest for reproductive and larval stages,
as indicated by limited laboratory evidence. Spawning of fathead minnow, for
example, has been shown to be affected significantly by exposure to 1.8 ug/1
(ppb) Aroclor 1254 in the water column (USEPA, 1976a).
Despite the high levels of PCBs that have existed in certain fish species,
in-river toxicological effects, such as fish kills, have not been confirmed in
the Hudson River. According to MPI (1980d), possible reasons for this are:
(1) The effects on particular segments of the aquatic life cycle are not
documented.
(2) Certain organisms may have developed a resistance to PCBs and other
Hudson River pollutants! as a result of long-term exposure.
Several health effects that may be related to contaminant levels have been
observed in the Hudson River (Kuzia, NYSDEC, January 21, 1981). Numerous gold-
fish collected over a 105-km (65-rai) stretch of the river were found to have
extensive skin ulcerations, possibly caused by the bacterium Aeromonas sal-
monicida. The disease also appears in golden shiners and black bass. Two
extensive mortalities of white perch have occurred, but a causative agent was not
discovered. A 25 percent incidence of liver tumors reported in Hudson River
tomcod may be related to PCB contamination. U.S. Fish and Wildlife Service
(USFWS) investigations have determined that striped bass fry and fingerlings
contaminated with PCBs have backbones that are considerably weaker than those
of fish from other waters. Through its possible effect on backbone strength,
PCBs. may reduce the ability of the young bass to compete for food and endure the
3-31
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stresses of migration and reproduction. The possible relationship between
contaminant levels and fin rot in the endangered shortnose sturgeon will be
discussed in section 5 of this chapter.
Potential Value of Fishery
If a full-scale fishery could develop on the Hudson River, it would have
substantial regional and local importance. Sheppard (1976) has estimated that
the Hudson River has the potential to produce an annual commercial finfish
harvest of 560,000 to 890,000 kg (1,240,000 to 1,960,000 Ib) with a value of
$261,000 to $426,500 (1976 dollars). Sheppard (1976) has estimated that a
recreational fishery in the upper Hudson River could support 100,000 man-days of
recreational fishing, with a corresponding economic value of $1,250,000 (1976
dollars). Sheppard has assigned an annual value of $1,350,000 (1976 dollars) to
the recreational fishery in the lower Hudson River.
4. TERRESTRIAL ECOSYSTEM
Below is a discussion of the terrestrial ecosystem at and around the pro-
posed containment site (Site 10). Additional information on the terrestrial
flora and fauna of the upper Hudson region is given in Hudson River Fish and
Wildlife Report [NYSDEC and USFWS, 1978]. (This report is on file at the five
designated depositories as a supporting document to this draft NEPA EIS.)
4a. Flora
The area of the proposed containment site is mainly agricultural, consisting
of planted and abandoned hay fields. Approximately half the site has not been
pastured or mowed for four to ten years. The western fields consist mainly of
grasses, milkweed, trefoil, three-square sedge, daisies, cow vetch, narrow leaved
cattail, and wild strawberries. The eastern portion of the site contains these
species, in addition to buttercups, St. John's wort, elm and cherry seedlings,
hard hack, and meadow sweet (MPI, 1980a). The northeastern portion of the site
has been abandoned long enough to have developed a young stand of slippery elm,
aspen and willow. Fence rows are lined with elms, white oak, shagbark hickory,
black cherry, ash and grey stemmed dogwood. The largest trees on the site are
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willows and elms, and several are up to approximately 1 m (3 ft) in diameter
(MPI, 1980 d).
Parts of the proposed containment site contain wet soils and are considered
to be wetlands under the New York State definition. Wetlands present on the site
include:
A 1.2 ha (3 a) seasonally wet grove of slippery elm
Linear wetlands totalling over 5 ha (12.34 a) in area along drainage
ditches, with wet meadow species such as rushed, sedges and cattail
A 1.2 ha (3 a) marsh at the foot of the shale ridge on the southeast
portion of the site, containing a diverse assortment of wetland shrubs,
sedges, ferns, rushes and mosses (MPI, 1980d).
The soils at the site have serious limitations for agricultural production
because they have low permeability and tend to be excessively wet. The rooting
depth of crops is usually limited to the upper 25 to 50 cm (10 to 20 in) of soil
because of a seasonal high water table and slowly permeable subsoil. Because
of the soil conditions, the site is more suited for the production of hay and
pasture mixtures that tolerate wetness than for the production of row crops. The
gently sloping areas of the site are subject to erosion, and the use of pasture
crops controls the loss of surface soil (MPI, 1980a).
Lands in the region of the proposed containment site are agricultural and
mainly utilized for production of dairy cattle. Corn, hay, and other crops for
use as animal feed are also grown in the area. Additional information on the
dairy industry of the region is given in section 4d of this chapter.
4b. PCS Levels in Terrestrial Flora
Terrestrial plants are known to absorb PCBs from the atmosphere. Background
atmospheric PCB levels resulted in detectable PCB concentrations in all the
foliage analyzed by Buckley (1980) in Washington and Saratoga counties. Con-
centrated sources of PCBs, such as PCB dumpsites, increase uptake by foliage in
surrounding vegetation within a radius of 500 to 700 m (1,600 to 2,300 ft). PCB
levels measured in foliage around PCB dumpsites are given in Table 3-6 and Table
3-33
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3-7. At the Fort Miller dumpsite, PCB levels of 58 ug/g (ppm) were found in
leaves adjacent to the site, and levels decreased to background levels, below
0.3 ug/g (ppm), approximately 700 m (2,300 ft) distant from the site. Elevated
PCB levels also exist around some roadways in the region. The PCBs may have been
derived from dredge spoil material that was used to sand roads in winter. PCB
levels also tend to be higher within a 2,000 to 4,000 m (2,200 to 4,400 yd) wide
margin on each side of the upper Hudson River (Buckley, 1980).
Levels of PCBs in roots tend to be comparable to levels in soil if the soil
is sandy and low in organic matter. PCBs are retained by organic matter and
clays, making the contaminant less accessible to uptake by plant roots (Buckley,
1980). If PCB-contaminated leaves fall to the soil and decay, the PCBs tend to
volatilize as the plant matter decays, rather than accumulate in the soil.
However, PCBs in leaves that are ploughed or disked into the soil would remain
there for several years at plough depth (Buckley, 1980).
There are differences in the degree to which different plant species absorb
PCBs. PCB levels derived from background atmospheric sources were found to be
0.03 ug/g (ppm) for alfalfa and 0.29 ug/g (ppm) for golden rod. For root crops,
carrots accumulate PCBs from the soil more than sugar beets and radishes. PCBs
are accumulated in the outer tissues of carrots and beets so that peeling removes
90 percent of the contaminant. However, PCBs are uniformly distributed in radish
(Buckley, 1980).
PCB levels in forage crops in Saratoga and Washington Counties are generally
well within the 0.2 ug/g (ppm) limit set by the FDA for PCBs in animal feeds. PCB
levels in forage crops grown near PCB sources, such as landfills and roads, have
been found to exceed the limit (Buckley, 1980). Additional information of PCB
crops of the region is in section 4d of this chapter.
Terrestrial plants are apparently able to tolerate high levels of PCBs
in surrounding soils and in their tissues. Native plants growing in 10,000 to
30,QOO ug/g (ppm) PCBs at the Fort Miller dump site show no visible symptoms of
3-34
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Table 3-6
Increases in Foliage PCS Levels
Location
Fort Miller
Dump Site
Caputo Dump Site
Bouy 212
Dredge Spoil Site
Moreau Dredge
Spoil Site
(Old Moreau Site)
Maximum Distance of
Foliage from Original
PCB Source
m (yd)
700 (770)
400+ (440+)
150 (170)
200 (220)
Range of Foliage
Concentrations
Within Area of
Elevated PCB
ug/g (ppm)
0.1 to 58
0.1 to 51
0.1 to 3
0.1 to 1.4
FDA Standard
for Forage
Crops
ug/g (ppm)
0.2
0.2
0.2
0.2
Source: Buckley, 1980.
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Table 3-7
Foliage PCS Levels Near fort Miller Dumpsite
Distance from
Dump site
m (yd)
73.5 (80.4)
89.0 (97.4)
132.1 (144.5)
Mean Weekly PCB
Concentration
in Air
ug/cu m
0.19
0.14
0.08
Corn, Grain
and Cob
ug/cu m
0.13
0.14
0.06
Corn, including Stem,
Leaves, .Ears and
Tassle
ug/g (ppm)
0.91
0.67
0.40
Alfalfa1
ug/g (ppm)
1.35
0.95
0.56
Red Clover 1>2
ug/g (ppm)
1 2
.Timothy '
ug/g (ppm)
3.2
2.4
1.4
u>
u>
Note 1. FDA standard for forage crops is 0.2 ug/g (ppm)
2. Estimates based on data for other crops
Source: Buckley, BTI, March 24, 1981.
-------
stress except those usually expected from water and nutrient deficiencies
(Buckley, 1980). Reduced plant growth, however, has been documented in a crop
species (soybeans) growing in soils containing 1,000 ug/g (ppm) Aroclor 1254
(Weber and Mrozek, 1979).
4c. Fauna
The terrestrial fauna at the proposed containment site consists of a variety
of birds and small mammals common to woodlots and fields. Likely inhabitants
of the area include opposum, racoon, porcupine, cottontail rabbit, whitetail
deer, several species of field mice, rats and moles, and numerous species of
birds. Burrowing animals that may be present include woodchucks, red fox,
skunk, muskrat, and weasel (MPI, 1980a). Because the land is not significantly
wooded, the area is not a preferred habitat for most of these animals, except
woodchucks, mice, rats, moles, and birds.
4d. Agriculture
Dairy farming is a major industry in the upper Hudson River region and
180 active farms are located within a 16-km (10-mi) radius from the proposed PCB
containment site. The dairy farms are small to moderately sized and are pre-
dominantly family owned. The approximate total investment for farm operation is
$4,000 to $5,000 per cow. .Replacement costs per cow are estimated at $1,000 to
$3,000 (Beaty, CAC, March 28, 1981).
. Most of the crops grown in the region, such as corn, alfalfa, clover, and
other forage crops are used to feed dairy cows. The selling value of these
crops is estimated at $18 to $23/t ($20 to $25/tn) for corn silage and $54/t
($60/tn) for grass hay. Cost to the farmer from a dealer is estimated at $32 to
$41/t ($35 to $45/tn) for corn silage and $54 to $73/t ($60 to $80/tn) for hay
(Beaty, CAC, March 28, 1981). The proposed containment site could yield 20 to 27
t/ha (9 to 12 tn/a) per year of corn for silage, or 5.4 to 9.0 t/ha (2.4 to 4.0
tn/a) per year of forage mixture. Such yields would sell for $370 to $74Q/ha
($150 to $300/a) per year.
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The pasture season, when the cows consume pasture forage, usually lasts from
May to October. During the remainder of the year, the cows eat winter rations of
corn silage and hay. The feed allowance for each mature Holstein is approxi-
mately 4.5 to 6 t (5 to 7 tn) of good hay-equivelent during the winter season and
5.5 to 7.5 t (6 to 8 tn) of good hay-equivalent during the pasture season. (One
unit of good hay is equivalent to three units of silage, or two units of hay-
lage.) A dairy cow generally remains in the herd for less than seven years.
Each cow has one lactation per year and produces 6,300 to 7,300 kg (14,000 to
16,000 Ib) of milk per year. A lactating cow drinks approximately 150 1 (40
gal) of water per day to produce milk that is approximately 87 to 90 percent
water (Newton, February 27, 1981).
As previously discussed, low levels of PCB are found in forage crops in
Washington and Saratoga counties. Measured PCB levels occasionally exceed the
FDA limit of 0.2 ug/g (ppm) in animal feed. There has been concern that milk
from cows consuming contaminated forage might exceed the FDA limit of 1.5 ug/g
(ppm) for PCBs in dairy products, especially because PCBs are known to con-
centrate in milk. Aroclor 1254 accumulates in milk by a factor four to five
times greater than the levels of 1254 in feed. But it has been determined that
milk produced in the region does not contain PCBs over the FDA limit, as in-
dicated by the following paragraph (MPI, 1980d).
The New York State Department of Agriculture and Markets has periodi-
cally sampled milk produced in Washington and Saratoga Counties for PCB
contamination. Most recently, potentially contaminated farming areas
were delineated by the State Department of Health (NYSDOH), and milk on
eight farms in these areas was tested for PCB on June 12, 1979. All
eight milk samples measured less than 0.2 ug/g total PCB on a fat
basis, well below the FDA standard of 1.5 ug/g ...
In addition to dairy products, poultry products, calves, heifers, pure
bred cattle, and relatively small quantities of cash crops are produced in
the region (Slocum, February 9, 1981; Stork, February 9, 1981).
5. THREATENED OR ENDANGERED SPECIES
A substantial population of endangered shortnose sturgeon exists in the
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Hudson River estuary. Most of the population probably occurs between Esopus
Meadows (River Mile 87) and the Troy Dam (River Mile 154). This reach of the
Hudson River encompasses the spawning area, the major overwinter area, the
important nursery area for young-of-the-year fish, and a substantial portion of
the summer feeding ground. Young-of-the-year shortnose sturgeon feed extensively
on benthic species between River Mile 140 and Kingston (River Mile 92) (Dovel,
Oceanic Society, February 23, 1981).
The vitality of the shortnose sturgeon population is probably more sus-
ceptible to harm from toxic chemicals introduced into the upper Hudson River than
any other species of fish inhabiting the estuarine ecosystem, including the
commercially valuable American shad and striped bass. The extreme vulnerability
of the sturgeon may be attributed to its occurrence and spawning in a highly
polluted 12.4-km (20-mi) segment of the estuary immediately south of the Federal
Dam at Troy (Dovel, Oceanic Society, February 23, 1981).
Approximately 75 percent of adult shortnose sturgeon over 75.0 cm (29.5 in)
in total length have fin rot. In some cases, this fin rot is very severe, but
the agent that causes the disease has not been positively identified. However,
high prevalence of fin rot has been shown to be associated with ecologically
degraded coastal areas (Murchalano, 1980). It is possible that toxic substances
in the water column lower the natural immunity of shortnose sturgeon to infes-
tations of a fungus, tentatively identified as Leptolegria caudata. For example,
PCBs have been shown to increase the number of virus infections in the pink
shrimp of the Gulf of Mexico (Murchelano, 1980). The fin rot common on adult
shortnose sturgeon in the Hudson River seems to be sublethal, but the disease
probably imposes a substantial stress on affected individuals (Dovel, Oceanic
Society, February 23, 1981).
The apparent low survival of newly fertilized eggs may be a critical factor
limiting the size of the shortnose sturgeon population in the Hudson River.
In 1979 and 1980, the hatching success of laboratory-reared eggs was greatly
impaired by the fatal penetration of fungus (Dovel, 1979). Eggs held in Hudson
River water became totally overwhelmed by the fungus in less than 24 hours,
whereas eggs held in spring water remained generally free of the fungus for a
much longer period.
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There seem to be substantial sublethal and lethal impacts on the shortnose
sturgeon that may indirectly result from a deterioration of the natural water
chemistry due, in part, to the presence of toxic chemicals, especially PCBs
(Dovel, Oceanic Society, February 13, 1981). A sturgeon with a concentration of
998 ug/g (ppm) PCBs in fatty tissue around the brain was alive when caught
(Dovel, 1980). However, there is no way to measure the sublethal stress experi-
enced by such contaminated fish. It is fairly obvious that the shortnose stur-
geon of the Hudson River is a bioaccumulator and bioconcentrator of PCBs and
probably other toxic chemicals, such as pesticides and heavy metals. The present
condition of the shortnose sturgeon population is unknown; it could be stable or
approaching collapse (Dovel, Oceanic Society, February 23, 1981).
No other rare or endangered species are known to inhabit the Hudson River,
and none are known to inhabit or frequent the area of the proposed containment
site. Protected species, such as the osprey and northern bald eagle, may pass
over the region during migrations through the Hudson River valley.
6. ENVIRONMENTALLY SENSITIVE AREAS
Areas that are classified as being environmentally sensitive include prime
agricultural soils, wildlife refuges, critical habitats of rare or endangered
species (as designated by USFWS), aquifer recharge areas, scenic or recreational
areas, floodplains, wetlands, cultural resources, and steep slopes.
Most of these categories either do not exist in this area or are not affect-
ed by any of the alternatives under consideration. Wetlands and the habitats of
rare or endangered species have been discussed in section 3 of this chapter.
Prime agricultural soils are not present on the property proposed to be acquired
for a containment facility. Cultural resources, scenic and recreational areas,
and floodplains will be discussed below.
6a. Cultural Resources
In conformance with federal and state laws and implementing regulations, a
preliminary cultural resource investigation (Stage I) was conducted for the PCS
containment facility at Site 10 in the Township of Fort Edward. The purpose of
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the investigation was to identify historic and archaeological properties on, or
eligible for listing on, the National Register of Historic Places.
The Stage I cultural resources study was conducted in the Township of Fort
Edward at the proposed containment site. The study was divided into two compon-
ents: a literature search (Stage la) and a field investigation (Stage Ib). The
literature search consisted of a detailed review of existing site files, inter-
views, deed research, examination of histories and maps, a walkover, and drive-
around the area. As a result of the literature search, the following resources
were identified within the project's proposed impact area:
trolley line (Hudson Valley Railroad right-of-way),
the Old Champlain Canal, a property listed on the National Register of
Historic Places,
old barn complex, and
house and barn complex.
The literature search also provided the data for the derivation of a his-
toric and prehistoric sensitivity model. From this preliminary inspection and
research, it was determined that a field investigation (Stage Ib survey) was
needed to identify prehistoric and historic archaeological site locations.
To locate archaeological sites, shovel test pits were placed at varying
intervals at selected locations within the project area. This sampling method-
ology was based on the derived sensitivity models.
Table 3-8 summarizes all cultural resources identified during the Stage
I study. No further work is recommended for those resources that do not appear
to meet the eligibility criteria for the National Register of Historic Places.
The archaeologically sensitive Dead Creek is outside the project impact zone
and will be avoided. Mitigation plans are presently being developed for the
Champlain Canal area. For the remaining eight cultural resources, further
investigation will be conducted in early spring. Historic structures will be
evaluated by a qualified architectural historian in consultation with New York
State Historic Preservation Office (SHPO). Subsurface testing will be conducted
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Table 3-8
Summary of Cultural Resources Identified at Site 10
Cultural Resource
Description
Recommendat ion
1. Historic Dump 1
2. Historic Dump 2
3. Old Barn Complex
4. Garage or Equipment Shed
5. New Barn Complex
6. House
7. Hudson Valley Railroad
8. Champlain Canal
9. Concrete Foundation
10. Stone and Concrete
Foundation
11. Hudson South
12. Hudson North
13. Dead Creek Bank
historic, surface
historic, surface
historic structure
historic structure
historic structure
historic structure
historic, destroyed
National Register Site
historic structure
historic
historic
prehistoric
prehistoric
prehistoric?
no further work
no further work
further identification
further identification
further identification
further identification
no further work
develop mitigation
plan
further identification
further identification
further identification
further identification
avoidance
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at the identified archaeological sites to evaluate their potential eligibility
for the National Register of Historic Places (Stage II).
6b. Scenic and Recreational Areas
Water quality class ificatons for the upper Hudson River vary from "A"
to"D." These classifications are based on the "best use" intended for these
waters (Appendix E). Except for the stretch of water from the mouth of the
Batten Kill to Lock 3 ("B"), and the section below Lock 2 ("A"), these waters are
intended for secondary contact recreation, primarily boating and fishing.
However, since 1976, commercial and recreational fishing have been prohibited in
the upper Hudson River between Fort Edward and the Troy Dam because of the high
PCB concentrations in fish (greater than 5 ug/g [ppm] PCBs). It has been es-
timated that the annual value of the recreation fishery in the upper Hudson River
would be $1,250,00 (in 1976 dollars) (Sheppard, 1976). The waters of the upper
Hudson River continue to be used by recreational boaters.
Recreational fishing is permitted in the lower Hudson River below the Troy
Dam. The taking ot American eel, however, is prohibited. Sheppard has assigned
an annual value of $1,350,000 (in 1976 dollars) to the recreational fishery in
the lower Hudson River. These waters are suitable for secondary contact re-
creation.
6c. Floodplains and Wetlands
The Hudson River between Troy and Glens Falls is bordered by terraced
proglacial lake deposits and bedrock cliffs. The floodplain of the upper Hudson
River in the area is long and narrow, confined largely to areas adjacent to the
river. The 100-year flood last occurred on April 2, 1976.
A small creek (Dead Creek) crosses the southeast corner of the. containment
site property. The extent of floodplain for this creek varies between 75 and 150
m (250 and 500 ft) from the center of the stream bed. Neither the Hudson River
floodplain nor the Dead Creek floodplain will infringe on the containment faci-
lity. Wetlands are found on the containment site and are described in section 4a
of this chapter.
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Several wetlands along the upper Hudson River have been designated as hot
spots. A discussion of these areas and their location is represented in section
3b of this chapter. Because of their value as wildlife habitats, several of
these wetlands should be retained, or restored, irrespective of any remedial
action involving the hot spots.
7. AIR RESOURCES
7a. C1imat e
The following section is an adaptation of Dredging of PCB-Contaminated River
Bed Materials, Upper Hudson River, New York (MPI, 1978a). The climate of the
upper Hudson River Valley from Glens Falls to the Troy-Albany area is generally
a humid continental type. Specifically, cold winters and warm, sometimes
humid, summers are typical. Mean minimum temperatures in January for. Glens
Falls and Troy are -12°C (10°F) and -9C (16°F), respectively. July mean
maximum temperatures for the same two locations are 30 C (86 F) and 28 C
(83 F) (United Stated Department of Commerce [USDC], 1974). Average annual
temperatures in 1976 for Glen Falls and Troy, were about 6 C (43 F) and 8 C
(47*F), respectively. The length of the freeze-free period for Glens Falls in
1976 was 135 days, extending from mid-May to the end of September. The freeze-
free period in Troy covered the period from mid-April to mid-October, for a total
of 182 days (USDC, 1976).
Precipitation in the Hudson River region is uniformly distributed throughout
the year. The minimum precipitation usually occurs during the winter months, and
the maximum during the summer months. For Glens Falls, mean annual precipita-
tion, calculated over a period of 20 years, is approximately 100 cm (40 in).
Mean annual precipitation for Troy ranges around 90 cm (36 in) (USDC, 1976). A
rainfall intensity-duration-frequency curve for Albany is depicted in Figure 3-1
(USDC, 1955). This curve indicates the frequency, in years, of a rainfall of a
given intensity in inches per hour and a given duration in minutes or hours.
The Hudson Valley generally has a continuous snow cover from mid-December to
mid-March, with maximum depths occurring in February. Mean total snowfall in
both Glen Falls and Troy is approximately 150 cm (60 in) per season (USDC, 1974).
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Figure 3-1
Rainfall Intensity-Duration-Frequency Curve* for
Albany, New York (1903-1951)
ta
ui
.02
MINUTES
DURATION
HOURS
Note: 1. Frequency analysis by method of extreme values, after Gumbel.
Source: a. MPI,. 1978a
-------
Within the Hudson River region, average pan evaporation and lake evaporation
have been calculated to be about 90 cm (35 in) and 70 cm (27 in), respectively
(USDC, 1959).
Wind speed and direction data for Glen Falls and Rensselaer are given in
Tables H-l and H-2 (Appendix H). Winds at the containment site are affected
by local topography and other conditions. However, local meteorlogical data
for the containment site is not: available.
7b. Air Quality
The following is an adaptation and update of Dredging of PCB-Contaminated
River Bed Materials, Upper Hudson River, New York (MPI, 1978a).
Total suspended particulates were monitored with high volume air samplers at
five stations in the general vicinity of the study area. These stations included
two in Glens Falls and one each in Fort Edward, Mechanicville, and Troy. At one
Glens Falls station and in Fort Edward, Mechanicville and Troy, both the annual
geometric means for 1975 through 1979 and the 24-hr average concentrations of
total suspended particulates were well under the state and federal standards
(Table 3-9). While the federal standard is uniform, state standards vary,
depending on the economic development and associated land uses of the region.
The other Glens Falls station did exceed the standard for the annual geometric
mean in 1975. The 1976 mean showed an improvement and subsequently, this site
was in compliance with the state standard of 55 ug/cu m for each successive year
through 1979. The 1979 24-hour maximum averages at all sites listed in Table 3-9
were well below the 250 ug/cu m standard (NYSDEC, 1979). Settleable particulates
are monitored in . Glens Falls and Troy with the use of 30-day dustfall jars.
These results are summarized in Table 3-10 (NYSDEC, 1979).
A PCB air sampling study has been undertaken at five locations in the upper
Hudson Valley. This program involves simultaneous sampling at each of the sites
every six days for 24 hours. Data in this program collected between January and
August, 1977 are presented in Table 3-11. The stations in Glens Falls and
Warrensburg recorded the lowest PCB values with readings generally less than
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Table 3-9
Total Suspended Particulates from High Volume Air Samplers at
Selected Stations, Upper Hudson River, 1979
Station
Glens Falls
Glens Falls
Fort Edward
Mechanicville
Troy
Federal
Standard
ug/cu m
75
75
75
' 75
75
NYS AAQS
Geometric Mean
Level
II3
III
II
II
III
ug/cu m
55
65
55
55
65
Annual Geometric Mean
(ug/cu ra)
(not to exceed AAQS G.M. )
1975
634
49
NA5
NA
46
1976
45
43
36
45
39
1977
41
45
33
39
36
1978
34
41
33
39
33
1979
37
45
36
44
36
24-hour Avg ug/cm m
(not to exceed
250 ug/cu m)
2
1st Max
90(0)
134(0)
144(0)
110(0)
71(0)
2nd Max
72
133
92
106
68
3rd Max
71
116
78
105
65
Co
Notes: 1. New York State standard for 24-hr average is 250 ug/cu m; federal standard is 260 ug/cu m.
2. 1st, 2nd and 3rd maximum averages measured during 1976. The number in parentheses
indicates number of times 24-hr max was exceeded.
3. The state is divided by air quality priorities into four levels: level I, denoting areas
of least pollution to level IV, areas of heaviest pollution. The two Glens Falls
stations are located in areas with different levels, thus the difference in the AAQS
values.
4. Denotes a violation of Ambient Air Quality Standards.
5. NA = Not Applicable.
Source: NYSDEC, 1979.
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Table 3-10
Settleable Particulates from 30-Day Dustfall Jars
Annual Averages 1976 to 1979 and Monthly Averages in
1979 at Selected Stations, Upper Hudson River
Station
Glens Falls
Troy
NYS
Annual
Standard
Level
II
III
NYS AAQS
Geometric Means
and 50/84
/ 2/
mg/cm /mo
0.30
0.40
mg/cm /mo
0.30/0.45
0.40/0.60
Annual Arithemtic Mean
,(mg/cm /mo)
1976
0.39
0.33
1977
0.26
0.23
1978
NA
NA
1979
0.23
NA
Monthly (30-day)
Avg.-19792
(mg/cm /mo)
Max
0.66
0.47
2nd Max
0.24
0.34
3rd Max
0.21
0.27
Notes: 1. 50th percentile value/84th percentile value.
2. Under monthly average 1979, the 1st, 2nd, and 3rd maximum 30-day averages were measured
from January 1 to December 31, 1979.
3. NA - Not Available. Insufficient data were available to formulate an annual arithmetic
mean.
Source: NYSDEC, 1979.
-------
Table 3-11
PCS Air Sampling by the New York State Department of Health
nannogram/cu m
Date
1/1/77
1/7/77
1/13/77
1/19/77
1/25/77
1/31/77
2/6/77
2/12/77
2/18/77
2/24/77
3/2/77
3/14/77
3/20/77
3/26/77
4/1/77
4/7/77
4/13/77
4/19/77
4/28/77
5/3/77
5/13/77
5/19/77
5/25/77
5/31/77
6/6/77
6/12/77
6/18/77
Stations
Glens Falls
5601-4
R
R
R
LA
R
<20
<20
<20
<20
R
<50
<20
R
<20
<20
<20
<20
<20
<20
<20
<20
<20
R
<20
<20
<20
R
Warrensburg
5660-02
R
LA
R
<30
<40
<20
<20
<20
<20
<20
<30
<20
<20
<20
<20
NR
<20
<20
<20
<20
<20
<20
<20
<20
<20
<20
R
Hudson Falls
5726-01
R
40
-------
Table 3-11 (continued)
Date
6/24/77
6/30/77
7/6/77
7/12/77
7/18/77
7/24/77
7/30/77
8/5/77
8/11/77
8/17/77
Stations
Glens Falls
5601-4
R
<20
<20
<20
<20
<20
<20
R
R
<20
Warrensburg
5660-02
<20
<20
<20
<20
<20
<20
<20
<20
<20
<20
Hudson Falls
5726-01
R
110
140
50
50
100
30
120
R
R
Fort Edward I
5755-01
R
3260-
1502
290
350
520
590
R
R
480
Fort Edward II
5755-02
30
<20
70
<20
<20
<20
<20
<20
R
<20
5601-04 = Continuous Air Monitoring Station, Glens Falls
5660-02 = DEC Region 5 Suboffice, Warrensburg
5726-01 = Main Street School, Hudson Falls
5755-01 = Washington County Office Building, Fort Edward
5755-02 = Fort Hudson Nursing Home, Fort Edward
1 nannogram = 1,000 micrograms
R = Reject
LA = Lab Accident
STB = Sampling Train Broken
NR = Not Run
Notes: 1. = Appear to have been switched but cannot be verified.
2. = Results are inconsistent with each other: 5726-01 is usually ten
percent of 5755-01.
Source: NYSDEC, 19771?.
3-49
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The Hudson Falls and two Ford Edward stations recorded higher PCB levels,
perhaps because of proximity to the GE facilities in Ford Edward. One Fort
Edward station, immediately northeast of the GE plant, recorded the highest
concentrations of the five stations, with values ranging from around 0.06 ug/cu m
to a maximum of 3.26 ug/cu m during the eight-month period. The other nearby
Fort Edward sampling station registered a maximum PCB value of 0.56 ug/cu m. The
mean PCB levels at this station were the second highest of the five stations.
Hudson Falls followed with monitoring results indicating PCB concentrations
significantly greater than Glens Falls and Warrensburg but less than the two Fort
Edward stations (NYSDEC, 1977).
Thirty-day dustfall jar tests, which are used to measure settleable particu-
lates, have also been conducted for three stations in Fort Edward, Glens Falls,
and Warrensburg (NYSDEC, 1977). Samples were collected monthly from February to
July 1977, and the results expressed as a total amount of PCBs per jar, PCBs per
gram of particulate matter, and amount of particulate matter per unit area.
In the two categories related to PCBs, the Fort Edward station was markedly
higher than the Glens Falls or Warrensburg stations.
Values of PCBs were less than 0.02 ug/cu m for each reading at Glens Falls
and Warrensburg, but ranged between 0.13 and 0.93 ug/cu m for the Fort Edward
station. Similarly, the micrograms PCB per gram particulate matter ranged
from less than 0.6 to less than 3.0 ug/cu m for Glens Falls and Warrensburg, but
from 8 to 29 ug/cu m at Fort Edward. The accumulation of particulate matter,
however, was only slightly greater at Fort Edward than at Glens Falls, while both
stations had considerably higher levels than Warrensburg.
These results indicate that settleable solids are more prevalent at Fort
Edward than Glens Falls and have much higher associated PCBs. Settleable
solids at Warrensburg are both reduced in quantity and less contaminated with
PCBs. The Fort Edward station is, again, located immediately northeast of the
the GE plant. It should also be noted that the above results are unpublished and
subject to revision.
3-50
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The following includes new information not previously reported in Dredging
of PCB-Contaminated River Bed Materials, Upper Hudson River, New York (MPI,1978a).
A field study was performed by NYSDEC (Tofflemire, 1981) on PCB concen-
trations at site 10 near the Delong Farm and the Lock 6 dam at the Cottrell Paper
Company (Table 3-12). The highest concentrations of PCBs were found at the Lock
6 Dam site for Aroclor 1016. The NYSDEC measured PCB concentrations outside the
Washington County Office Building in Hudson Falls, New York from November 1976
to December 1977 (Figure 3-2). As evidenced by the figure, the average PCB
concentration dropped from approximately 1 ug/cu m to about 0.3 ug/cu m after
the cessation of PCB use at the GE plant in July, 1977.
NYSDEC measured PCB concentrations in air at several sites in the Fort
Edward and Hudson Falls area (Table 3-13). As indicated by the table, it appears
that the highest PCB concentrations occurred at the Caputo Dump site. However,
some discrepancies in sampling method and duration have been noted and as a
result, these data may not be appropriate for the purpose of comparisons.
3-51
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Table 3-12
Ambient PCB Levels at Site 10 and Lock 6 Dam
Site
Site 10 by Delong Farm
Site 10 by Delong Farm
Lock 6 Dam at Cottrell
Paper
Lock 6 Dam at Cottrell
Paper
Date
8/25/80
8/26/80
9/05/80
9/07/80
8/25/80
8/27/80
9/05/80
9/07/80
Hrs. of Sampling
19 1/2
48
48
48
PCBs ug/cu m
Aroclor
1016
<.02
<.01
<.ll
<.52
1221
<.02
<.01
<.01
<.01
1254
<.02
<.01
<.01
<.01
Source: Tofflemire, NYSDEC, March 11, 1981
3-52
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Figure 3-2
PCB CONCENTRATIONS IN AMBIENT AIR AT WASHINGTON COUNTY OFFICES
___ average PCB concentration
before and after July 1977
4.0-
2.0-
1.0-J
3
U
*^
60
3
8
PM
0.2-
0.1-
Cessotlon of PCB
use.at GE
I. I T 1 I I I I I I I I I
Nov Dec Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
1976
1977
-ample collection by NTS. DEC
PCB onalyili by N.Y.S. OOH
-------
Table 3-13
Summary Tabulation of Aiir PCS Data by NYSDEC Division-of Air Resources
Data taken at Temperature of 18 to 29 ° (65 to 85°F)
Site
Caputo Dump
Caputo
Fort Miller Dump
Remnant Area
Moreau site with
excavated 3A
material
Buoy 212 site
Summer 1979
Old Moreau Site
Summer 1979
Comment
Max
Avg
Max
Avg
Max
Avg
Max
Avg
One Sample
29° (85°F)
Avg
Air PCB
ug/cu m
300
130
35
24
10
9
15
5.6
0.7
0.3
Sediment
ug/g (ppm)
10,000-50,000
10,000-50,000
5,000-15,000
5,000-15,000
1,000-2,000
1,000-2,000
600-1,000
600-1,000
50-100
20-50
3-53
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CHAPTER 4
Environmental Consequences
of Feasible Alternatives
-------
CHAPTER 4
ENVIRONMENTAL CONSEQUENCES OF FEASIBLE ALTERNATIVES
This chapter presents a discussion of the environmental impacts of the
feasible alternatives proposed to address the PCB problem that exists in the
Hudson River. The evaluation will draw on the alternatives presented in Chapter
2 and the scientific evaluations presented in Chapter 3 of this document. How-
ever, the environmental impacts of all the options discussed in Chapter 2 are
not presented because some were found to be infeasible and/or ineffective.
Specific alternatives, including Control of River Flows, In-River Detoxifi-
cation, Physical Treatment/Destruction of Dredged Spoils, and Bank-to-Bank
Dredging were found to be infeasible because of costs and technical consid-
erations and are not analyzed further.
The remaining alternatives, including No-Action (with and without routine
maintenance dredging), Dredging Alternatives (the Full-Scale Project and Reduced-
Scale Project), In-River Containment of Hot Spots, Remnant Deposit Alternatives,
Dredging Mechanism Alternatives, and Dredge Spoil Disposal Alternatives, were
evaluated for potential beneficial and adverse, short- and long-term impacts
under normal river flow as well as high-flow conditions. By definition, primary
impacts are those adverse or beneficial impacts that are associated with the
construction and operation of a proposed project. Secondary impacts are those
adverse or beneficial impacts that are induced or result indirectly from the
proposed project. The major factors considered in the assessment of primary and
secondary impacts are:
Public Health
- Protection of downstream water supplies
Reduction of volatilization from remnant deposits and dredge spoil areas
Reduction of containment site volatilization
Reduction of exposure through the ingestion of contaminated fish
- Protection of groundwater in the area of the containment site
Fisheries and Aquatic Biota
Permanent reopening of the commercial and recreational fisheries
- Protection of endangered species (shortnosed sturgeon)
- Reduction of the bioaccumulation of PCBs through the food web
Protection of wetlands;
4-1
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Maintenance Dredging and Navigation
)
- Mitigation of future maintenance dredging and disposal problems in the
upper Hudson Basin as well as the estuary
- Evaluation of impacts to future hydroelectric dam construction and
usage
Agriculture
Reduction of volatilization from remnant deposits and dredge spoil
areas
Reduction of containment site volatilization
Protection of groundwater in the area of the contaminant site
- Protection of crops and livestock in the area of the containment
site
The recommended action is comprised of the following alternatives:
Full-Scale Project, Major Alternatives section 4 (if funding becomes
available)
Reduced-Scale Project, Major Alternatives section 5
In-River Containment, Alternative Components section 1 (wherever cost-ef-
fective)
Containment Site, Alternative Components section 4
I. MAJOR ALTERNATIVES
1. The No-Action Alternative
1A. No-Action Alternative (Assuming That Routine Channel Maintenance
Dredging Will Continue)
la. Short-term Primary Impacts
Under this alternative, there will not be adverse short-term primary impacts
because PCB-contaminated sediments will not be removed from the Hudson River.
This alternative does not provide for the stabilization and/or removal of remnant
deposits, or the removal of NYSDOT Spoil Site 204 Annex. In short, this no-
action alternative would allow the total mass of PCBs to remain in the banks
and bed of the Hudson River, except for that removed by maintenance dredging,
volatilization and transport downstream. The continued dispersion of PCB in
such a way could present long-term adverse impacts, as described below.
4-2
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The beneficial primary impacts of this alternative include the avoidance of
short-term construction related effects such as noise, truck traffic, destruc-
tion of wetlands and resuspension of sediments.
Ib. Long-term Primary Impacts
Under this no-action alternative, long-term adverse impacts can arise
because the total mass of PCBs will remain in the Hudson River system, allowing
the continual release of the toxic chemical to the air, water and biota.
Routine maintenance channel dredging and volatilization will remove PCBs from
the river. Table 2-2 indicates that it would take 33 years from the present
date for all the PCBs in the upper Hudson River either to be transported into
the estuary, to be volatilized, or to be removed by routine navigational dredg-
ing. Under this no-action alternative, 82,800 kg (182,000 Ib) would be carried
over the Federal Dam at Troy, 22,500 kg (49,500 Ib) would be volatilized, and
37,400 kg (82,500 Ibs) would be removed by routine maintenance dredging.
The long-term primary impacts that could arise from this no-action al-
ternative include: potential long-term threat to downstream public water supply;
continued risk to the public associated with exposure to PCBs from uncontrolled
volatilization and direct contact; continued availability of PCBs to the food
chain from both the terrestrial and aquatic media; continued threat to the
commercial and recreational fisheries of the Hudson River; and a threat to the
continuation of routine maintenance dredging operations.
Public Health
An evaluation of the impact of the no-action alternative on public health
should include a definition of background levels of PCBs in all media that lead
to human exposure and an evaluation of the toxic effects and health impacts
associated with such exposure. Routes of exposure include drinking water,
inhalation, ingestion, and dermal absorption. Routes and degrees of absorption
of PCBs through the skin are unknown, and exposure through this route is unquan-
tifiable, although subjectively estimated to be small relative to other exposure
routes. (Appendix A).
4-3
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As described in section 2 of Chapter 3, background levels of PCBs in the
Hudson River are approximately 0.6 ug/1 (ppb) and have remained steady through
the three monitoring years of 1977, 1978, and 1979 (Tofflemire, NYSDEC, 1980).
Water treatment by activated carbon filtration can reduce these levels by 40 to
80 percent (Cranston, City of Poughkeepsie, August 25, 1977), but such treatment
is presently not used by Hudson River communities. Residents using treated
Hudson River water for consumption would consume about 0.6 ug/day of PCBs (at a
consumption rate of 2 liters/day [Ipd]). Residents consuming untreated river
water, could be exposed to levels of up to 1.2 ug/day. This situation could
become worse and actually increase in areal extent under a flood situation where
PCB-laden sediments from hot spot areas would be resuspended and carried further
downstream.
Based on comprehensive national food surveillance programs from 1971
through 1975, FDA has estimated the average daily intake from all food group
composites and the average daily intake from the meat-fish-poultry class (Table
4-1). The decrease in total dietary exposure is due to decreasing levels of
PCBs in food packaging materials. The ingestion of PCBs through food should
level out (based upon national background levels) and continue at the 1975 level
as long as fish remain almost the sole source of dietary PCBs.
The populace in Fort Edward and Hudson Falls is exposed to an outdoor
general background PCB concentration of 0.05 to 0.10 ug/cu m (Kerr, NYSDEC, May
8, 1980) and the rural populance is exposed to concentrations of less than 0.01
ug/cu m (Buckley, BTI, April 9, 1981). Residents and livestock in the area of
existing PCB dumpsites and dredge spoil disposal sites and remnant sites can be
exposed to levels above background levels. For example, at several PCB dump
sites in the Fort Edward and Glens Falls areas, concentrations exceeded the NIOSH
8-hour recommendation of 1 ug/ cu m, with levels at the Caputo site of up to 130
ug/cu m during the summer (MPI 1980d). Soil concentrations of PCBs at the Caputo
site were 10,000 to 50,000 ug/g (ppm).
As discussed later in this chapter, the general public health risks asso-
ciated with the no-action alternative are greater than those associated with any
of the feasible action alternatives.
4-4
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Table 4-1
Estimates of Total Daily PCS Ingestion
Fiscal Year
1971
1972
1973
1974
1975
Average Daily Ingestion of PCBs (ug/day)
Total Diet
15.0
12.6
13.1
8.8
8.7
Meat-Fish-Poulty Class
9.5
9.1
8.7
8.8
8.7
Source: EPA, 1976b.
4-5
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Fisheries and Aquatic Biota
Under the no-action alternative, contamination of fish in the Hudson River
will continue. Based on 1980 data, most fish species in the upper Hudson River
contain PCBs at levels exceeding the FDA tolerance level of 5 ug/g (ppm). A
number of species in the lower Hudson River, including striped bass, white
perch, and eel, also contain PCBs above the FDA standard (Appendix G). As
discussed in Chapter 3, section 3, PCB levels in Hudson River fish have sub-
stantially declined since testing began in 1976 and 1977. Collective decreases
in total PCBs averaged 38 percent from 1977 and 1978 (Armstrong and Sloan,
1980). The overall decline was mainly caused by decreases in Aroclor 1016,
which is less stable in the environment than the more highly chlorinated aro-
clors. The 1980 fishery data indicate that the decline in fish PCB levels
may be leveling off. Aroclor 1016 continued to decline, but Aroclor 1254 de-
clined very little, if at all, from 1979 to 1980 (Sloan, NYSDEC, March 10,
1981).
Under the no-action alternative, it seems likely that PCB levels will not
decline to the acceptable limit until the late 1980s at the earliest. For
largemouth bass and other resident fish in the upper Hudson River that have PCB
levels well above the limit, PCB levels would decline to below 5 ug/g (ppm) in
approximately five or six years, assuming that the rate of decline over the past
three years continues. In the lower Hudson River, resident fish, such as white
perch and some striped bass, would not have acceptable PCB levels until the late
1980s at the earliest. However, the rates of decline that occurred from 1977
to 1980 probably will not continue because the declines were mainly due to the
cessation of PCB discharges by GE, the low flow conditions on the river, removal
of some contaminated materials by maintenance dredging, and by the removal of
remnant deposit 3A, the stabilization of remnant deposits, and the breakdown of the
lower chlorinated aroclors. PCB levels in fish may tend to stabilize around a
level in equilibrium with levels of PCBs released from river sediments. If a
future flood causes extensive resuspension of PCB contaminated sediments,
declines in PCB levels in fish could be halted or even reversed. There is
evidence that fish can accumulate PCBs from the water column quite rapidly
4-6
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(Armstrong and Sloan, 1980). A flood event that elevates PCB levels in the
Hudson River for one to two weeks could cause increases in fish PCB levels. PCBs
accumulated in such a way would persist in the fish indefinitely because of the
long retention time of PCBs in fish flesh.
Under the no-action alternative, it is unlikely that PCB levels in fish will
reach the FDA limit that would allow the fishery to be reopened during the
next ten years. The continued release of PCBs from sediments and the likelihood
of floods could combine to keep the fisheries closed. The lowering of the limit
to 2 ug/g (ppm), as proposed by FDA, would keep the fishery closed indefinitely.
The one exception is American shad. Mean PCB levels in shad were found to be
below 5 ug/g (ppm) when testing began in 1976. After significant declines from
1976 to 1978, PCB levels in shad seem to have stabilized around 1.5 ug/g (ppm)
(Appendix G).
Contamination of Hudson River fish will continue to impose health risks on
the .public. Despite the ban on fishing, illegal commercial fishing, sport
fishing and subsistence fishing do take place on the Hudson River, and consumers
are eating fish with PCB levels exceeding the FDA limit (Blumenthal, New York
Times, April 3, 1981).
Since FDA data collected in 1975 indicate that the meat-fish-poultry food
category is primarily responsible for dietary intake of PCBs, suspension of the
ban on fishing in the upper Hudson River must be considered for its effects on
local population dietary exposure to PCBs. For people along the Hudson River
that do not consume fish taken directly from the river, exposure to PCBs through
the ingestion of food would be at least 9 ug/day, the national background level
(USEPA, 1976b). Consumption of Hudson River fish with PCB levels at the FDA
action level of 5 ug/g (ppm) would increase this level to approximately 900 ug/day,
based upon an average daily consumption of 200 grams (0.4 Ibs) of fish (USFDA, 1979)
Agriculture and Terrestrial Biota
The no-action alternative would allow the continued volatilization of PCBs
from remnant deposits, from the banks and bed of the Hudson River, and from
existing dredge disposal sites. This situation poses a potential threat to the
4-7
6:A-08
-------
dairy industry immediately adjacent to these uncontrolled disposal sites through
the volatilization process. Forage crops contaminated with PCBs could be in-
gested by dairy cows, increasing the risk that milk could be contaminated with
PCBs. Another agricultural concern associated with the no-action alternative
regards the potential risk of using Hudson River water (without treatment) for
dairy herds.
Volatilization from existing PCB sources will also continue to contaminate
adjacent flora and fauna, allowing biomagnification of PCBs to occur in the
terrestrial ecosystem.
Maintenance Dredging and Navigation
The USACOE requires toxicity testing of dredge spoils before permitting
ocean disposal. Such tests have indicated that PCB concentrations greater
than 4 ug/g Cppm) in dredge spoils would likely preclude ocean disposal, es-
pecially if heavy metals and other toxic contaminants are present (Curll, Save
Our Ports, March 24, 1981). There are sediments in areas of the lower Hudson
River which are not now suitable for ocean disposal. PCB levels in the Albany
turning basin are expected to continue to increase until the year 2013 under
this alternative. This would preclude ocean disposal of these dredge spoils.
At present the average PCB concentration in New York Harbor is 3 ug/g Cppm) with
some areas exceeding 4 ug/g (ppm) (Bopp, 1981). The average PCB concentation in
New York Harbor sediments is expected to increase under the no action alter-
native, but local increases in PCB concentrations are likely to occur.
A beneficial impact associated with the no-action alternative (assuming
that routine maintenance channel dredging will continue) is that, although the
removal of PCB-contaminated sediments as proposed by the NYSDEC would not be
implemented, future routine maintenance dredging operations would inadvertantly
remove PCB contaminated sediments from the channel. In effect this will remove
approximately 37,400 kg (82,400 Ibs) of PCBs from the ecosystem. However, this
could present the potential adverse effects from disposal practices involving
multiple upland containment sites.
4-8
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Ic. Secondary Impacts
The no-action alternative will have several adverse secondary impacts.
The continued contamination of Hudson River fishes and the partial closing of the
fisheries will cause a continued loss of income and employment for the region
that would occur if the commercial fishery were fully opened. Closure of the
recreational fishery in the upper Hudson River also represents a loss of income
that would otherwise be generated by the sale of fishing equipment, bait, gaso-
line and other expenditures by sport fishermen.
The contamination of drinking water supplies with PCBs to unacceptable
levels during a flood event will also have adverse secondary impacts under the
no-action alternative. The costs of additional water treatment measures, such
as activated carbon filtration, or costs of providing alternative supplies of
water, would be an economic burden to communities or private individuals if such
contamination occurs.
If dredge spoils from the lower Hudson River cannot be disposed of in the
ocean, substantial economic hardship would be imposed on port areas because
alternative methods, such as land disposal, are much more costly. Maintenance
dredging in the upper Hudson River could also become much more costly if highly
contaimnated dredge spoils must be held in a safe containment facility instead of
a usual dredge spoil site.
The no-action alternative could have secondary impacts on agriculture if
contamination of forage crops leads to excessive PCB levels in milk, rendering it
unmarketable. This is not a likely impact of this alternative, however, because
contamination of forage crops probably will not become worse in the future. PCB
levels in milk from the region have not exceeded FDA tolerance limits.
The no-action alternative could have adverse secondary impacts on the
development of hydroelectric power in the region. Under the no-action alter-
native, loss of PCBs from remnant deposits would be greatly accelerated if a
surging dam were constructed at Fort Edward by NMPC, as discussed in section
2 of Alternative Components, Chapter 2. All or some of the remnant deposits
4-9
-------
would have to be removed or adequately stabilized before construction of a
surging dam. This would represent a possible impediment to the development of
hydroelectric power in the Fort Edward region.
Id. Unavoidable Adverse Impacts and Steps to be Taken to Minimize
Harm
The no-action alternative poses substantial risks to the fishery, to dis-
posal of dredge spoils from the estuary, and to public health. The only possible
mitigating measure is to control the flow in the upper Hudson River to reduce
the resuspension and transport of PCBs. This could be done with very limited
effect-
iveness at the Conklingville Dam and is not recommended for addressing the
existing PCB problem in the Hudson River.
le. Contingency Plans
In the event that a potable water supply were contaminated with PCBs
at concentrations greater than 1 ug/1 (ppb), a filtration system or alternate
sources of water would be necessary.
If. Monitoring
Monitoring of the PCB levels in fishes of the upper and lower Hudson
River will be necessary to know when to reopen the fishery. Monitoring PCB
concentrations in sediments prior to dredging will enable dredging to occur
before those concentrations preclude ocean dumping. Monitoring programs
must be established during flood conditions to protect water supplies for
down-river communities utilizing the Hudson River for municipal water.
IB. No-Action Alternative (Assuming That Routine Channel Maintenance
Dredging Is Halted
Primary and secondary environmental impacts for this scenario of the
no-action alternative are similar to those discussed under the no-action alter-
native, Chapter 4, section I.1A. Table 2-3 indicates that 112,000 kg (247,000
Ib) of PCBs would be transported into the estuary over 48 years. This can
4-10
-------
be compared with 82,800 kg (182,000 Ib) of PCB transported into the estuary over
33 years for the no-action alternative assuming that maintenance dredging will be
continued.
Table 2-3 indicates that, if routine channel maintenance of the upper
Hudson River were to cease, it would take 48 years from the present date for all
the PCBs in the upper Hudson River either to flow into the estuary, or to vola-
tilize. Under this scenario 112,000 kg (247,000 Ib) would be carried over the
Federal Dam at Troy, and 33,300 kg (73,500 Ib) would be volatilized. Both
no-action alternatives (with and without routine channel maintenance) have
similar impacts, except that it is more likely that an adverse event will occur
under the no-action alternative without maintenance dredging. Routine channel
maintenance in the upper Hudson River is likely to be halted unless a containment
area is available for dredge spoils with concentrations greater than 50 ug/g
(ppm) of PCBs. The cessation of maintenance dredging could create a significant
economic hardship on upper Hudson River communities because alternative trans-
portation systems would be more costly.
The mitigating measures;, contingency plans and monitoring requirements
discussed under section I.1A of this chapter would also apply to this no-action
alternative.
2. Control of River Flowis
This alternative was found to be infeasible, as discussed in Chapter 2.
3. In-River Detoxification
This alternative was found to be infeasible, as discussed in Chapter 2.
4. Full-Scale Project
The full-scale project involves the removal of hot spots by hydraulic or
mechanical means, the disposal of the dredge material in the containment area,
the in-river stabilization of selected hot spots, and mitigative actions at the
4-11
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remnant deposits. Impacts will occur with each aspect of the full-scale project.
To avoid repetition, short-term impacts associated with the various dredging
methods that could be used in the full-scale project are discussed in section II
of this chapter (Alternative Components). Similarly, the impacts associated
with the containment of the dredge spoils and the remnant deposit alternatives
are also discussed in section II. Only the long-term impacts arising from the
removal of PCBs from the "Hudson River under the full-scale project will be
discussed in this section.
4a. Short-term Primary Impacts
The primary impacts of the full-scope project are short term impacts
related to the dredging methods, remnant deposit actions and other alternative
components utilized in the project. These impacts will be discussed in section
II of this chapter.
4b. Long-term Impacts
Public Health
The full-scale project will have beneficial long-term impacts on public
health. The quality of drinking water for communities utilizing the Hudson
River water will improve. Although the current PCB drinking water guideline (1
ug/1) is presenlty being met, removal of contaminated sediments will further
reduce present concentrations. A corresponding reduction in health risks will
follow.
Volatilization of PCBs from the river, remnant deposits and other sources
will be signficantly reduced. Direct contact of the public with PCB-contami-
nated deposits, particularly at the remnant deposits, will be reduced. The
risks associated with exposure to PCBs by the public will therefore decrease.
As discussed below, removal of PCBs from the Hudson, River under the full-
scale project will reduce the amount of PCBs available for uptake by fish. A
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reduction of PCS levels in fish would have a beneficial impact on public health
because it would reduced the dietary uptake of PCBs by the public.
Fisheries and Aquatic Biota
Monitoring by NYSDEC from 1976 to 1980 indicates that PCB levels in Hudson
River fish have declined. If the trend continues, it is possible that PCB
levels below the FDA tolerance limit of 5 ug/g (5 ppm) could be achieved by the
end of the 1980s and that the fishery could eventually be opened completely.
However, if contaminated sediments were resuspended by a major flood event, PCB
levels could remain high and the fishery would remain closed. Under normal flow
conditions, the full-scale project has the potential to accelerate the decline in
PCB levels and the recovery of the fishery. The project also has the potential
to reopen the fishery permanently even under future flood conditions.
The full scope project may also directly benefit fish populations in the
Hudson River. There is limited evidence indicating that PCB-contamination has
adverse effects on the survival and reproduction of certain fish species,
including striped bass.
The endangered shortnose sturgeon could benefit by a reduction of PCB
contamination in the river. Damage from PCBs has been linked to susceptibility
of the shortnose sturgeon popoulation to fin rot disease.
Some PCB hot spots are in wetlands and their removal would have adverse
effects on food chain relationships and breeding habitats. Several wetland areas
containing hot spots may be affected if these areas are diked or stabilized in
place. This action may initiate a succession of the vegetation from shallow to
deeper rooted plants, thus changing the aquatic and terrestrial fauna. Removal
of PCB-contaminated sediments would have the favorable impact of reducing the
bioaccumulation of PCBs through the wetland food web.
Agriculture and Terrestrial Biota
Under the full-scale project, removal of PCBs from the river bed and banks
will decrease volatilization and the resulting contamination of adjacent terres-
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trial flora, including forage crops. Contamination of forage crops represents a
potential risk to the dairy industry because PCBs tend to concentrate in cows
and milk. The full-scale project will decrease this risk. A reduction in
volatilization will also decrease the extent of biomagnification of PCBs through
terrestrial food chains.
Maintenance Dredging and Navigation
The full-scale project will result in an overall beneficial impact on
maintenance dredging and navigation.
In the upper Hudson River, continued maintenance dredging will be assured
if concentrations in dredged material can be reduced to less than 50 ug/g (ppm).
A piecemeal approach to the disposal of dredge spoils from maintenance dredging
will be prevented by providing secure and localized containment for a substantial
portion of contaminated sediments. Continued maintenance dredging will also
ensure that future navigation is maintained in the upper Hudson River. The
full-scale project will also reduce the chance that the PCB content of sediments
in the lower Hudson River, especially in the Albany turning basin, will increase
to levels that would require upland containment of dredge spoils.
4c. Secondary Impacts
The full-scale project will have beneficial secondary impacts. The project
has the potential to reduce PCB contamination of Hudson River fish and to hasten
the complete reopening of the fisheries. Complete reopening of the commercial
and recreational fisheries would have significant economic benefits by creating
additional employment and income for residents and businesses of the area.
The full-scale project will also have the beneficial impact of ensuring
that maintenance dredging will not be halted because of excessive contamination
of sediments in the upper Hudson River. The economic hardships that would occcur
if segments of the river system presently used for barge and other boat traffic
became unnavigable would not occur. In addition, the economic hardships that
could result from a halt of ocean disposal of dredge spoils from the lower Hudson
River may also be avoided.
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The full-scale project will facilitate the construction of a hydroelectric
dam at Fort Edward. The costs of removing the remnant deposits will no longer be
an impediment to construction of the dam and development of hydro-
electric power.
4d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize
Harm
Except for the maintenance of a containment facility for dredge spoils,
the long-term impacts of the full-scale project will be mainly beneficial and
mitigating measures are not needed. If valuable wetlands are destroyed by
removal or containment of hot spots, however, a mitigating measure would be the
restoration of the wetland. Restoration of a wetland through the planting of
wetland vegetation and other reconstruction measures would be especially im-
portant if the wetland is a valuable wildlife habitat or breeding and nesting
area for waterfowl.
Mitigating measures applicable to the construction and operation of a con-
tainment facility are discussed under Alternative Components, section II.4. of
this chapter. Mitigating measures for the adverse impacts of the dredging
components will also be discussed in section II, as will the mitigating measures
associated with the remnant deposit alternative.
4e. Contingency Plans
The full-scale project will substantially reduce the risk that drinking
water supplies derived directly or indirectly from the Hudson River could become
contaminated by PCBs after a major flood. However, contingency plans should
provide for alternate supplies of water or adequate purification systems for
residents if PCB levels were to exceed acceptable limits in water supplies.
Contingency plans for the operation of a containment facility for the
dredge spoils will be discussed in section II of this chapter. Short-term con-
tingency plans for the dredging and remnant deposit components of the full-scale
project will also be discussed in section II.
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4f. Monitoring
Extensive monitoring will be required during the construction and operation
of the containment facility (section II, Chapter A).
Long-term monitoring of river water for PCBs and heavy metals must be per-
formed downstream of removed hot spots to determine the effectivensss of the
removal operation. PCB levels in vegetation adjacent to the upper Hudson River,
particularly near dams and locks, should also be monitored at least at yearly
intervals. Particular attention should be given to forage crops. PCB levels }.n
Hudson River fish must also be monitored to determine if PCB levels have declined
enough to permit the reopening of the fishery.
5. Reduced-Scale Project
The reduced-scale project involves the removal of selected hot spots by
hydraulic or mechanical means, the disposal of the dredge spoils in the contain^
ment area, and mitigative actions at the remnant deposits. To avoid repetition.
short-term impacts associated with the various dredging components that could be
used in the reduced-scale project are discussed in section II of this chapter.
Similarly, the impacts associated with the containment of the dredge spoils and
the remnant deposit alternative are also discussed in section II.
5a. Short-term Primary Impacts
The short-term primary impacts of the reduced-scale project are impacts
related to the dredging methods, remnant deposit actions and other alternative
components utilized in the project. These impacts will be discussed in section
II of this chapter.
5b. Long-term Primary Impacts
The long-term impacts associated with removal of contaminated sediments
from the upper Hudson River under the reduced-scale project are essentially the
same as those of the full-scale project. The reduced scale project will have
beneficial impacts on public health, fisheries and aquatic biota, agriculture
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and terrestrial biota, and maintenance dredging and navigation. However, the
magnitude of these impacts will be less under the reduced-scale project because
the amount of contaminated sediment removed from the river system will be less.
The long-term adverse impact on wetlands discussed under the full-scale
project will not occur under the reduced-scale project. Under the reduced-scale
project, hot spots in valuable we:tlands will not be removed.
5c. Secondary Impacts
The reduced-scale project will have beneficial economic impacts associated
with the Hudson River fisheries, maintenance dredging, and ocean disposal of
dredge spoils. The secondary impacts of the reduced-scale project will be
essentially the same as those for the full-scale project (section 1.4 of this
.chapter). .The magnitude of the impacts, however, will not be as large because
the amount of PCBs removed from the river system will be less under the reduced-
scale project.
5d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize
Harm.
Mitigating measures for the reduced-scale project are the same as those for
the full-scale project, with the exception that restoration of wetlands will not
be necessary since the reduced-scale project would avoid dredging of ^hje-wetland
hot spots.
5e. Contingency Plans
Contingency plans for the reduced-scale project are the same as those
for the full-scale project.
5f. Monitoring
The monitoring program for the reduced-scale project will be identical to
that for the full-scale project.
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6. Bank-to-Bank Dredging
This alternative was found to be infeasible, as discussed in Chapter 2.
II. ALTERNATIVE COMPONENTS
1. In-River Containment
The in-river containment alternative involves isolation of selected hot
spots with dikes, bulkheads and backfilling. The purpose of in-riyer con-
tainment is to prevent erosion of the hot spots and reduce the release of PCBs to
the river.
1A. Short-term Primary Impacts
Public Health
The in-river containment alternative will expose workers at the work sife t;p
potential health risks. Air concentrations of PCBs at the hot spots could be
greater than 1 ug/cu m, the NIOSH 8-hour recommendation, but well below the 50P
ug/cu m OSHA standard. The health effects of exposure to airborne PCBs are dis-
cussed in Appendix A.
Short-term health risks could be imposed on the public if construction
activities cause an increase in releases of PCBs to the air or water. Releases
of PCBs are likely to occur through the following processes:
Construction of containment structures such as dikes will require dredg-
ing of PCB-laden sediments in order to prepare a firm substrate as a
base. The dredged sediments must be either transplanted to the in-^river
contained area or to an upland containment site. Dredging will resuspend
sediments and cause release of PCBs to the river and air. The impacts of
dredging are discussed in section II.3 of this chapter.
Erosion and scouring of PCB-contaminated sediments could increase during
the construction phase because vegetation and sediments will be disrupted
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by machinery, boat movements and other construction activities.
Other construction related activities, such as the movement of tug boats
in shallow water, will resuspend sediments and PCBs.
During the construction phase, volatilization of PCBs will increase as
previously buried hot spiot sediments are exposed to the air or water.
Releases of PCBs to the water and air from construction should be low and of
short duration, so public health effects should be minimal.
The construction equipment required for in-river containment will create
substantial noise that may disturb nearby residential areas. The equipment will
also produce minor amounts of air pollution. These impacts will be of short
duration and should not create any significant public health problems.
Fisheries and Aquatic Biota
Releases of PCBs to the river from construction activity will make the
contaminment available for accumulation by fish. Because the releases are ex-
pected to be small and of short duration, the effects on fish of in-river con-
tainment should not be significant. Benthic organisms in close proximity to
construction activity, however, may be harmed or killed by local siltation.
Existing wetland vegetation and wildlife habitats at and adjacent to areas
where containment structures are to be placed will be destroyed.
Agriculture and Terrestrial Biota
The construction equipment will create substantial noise and disrupt nearby
wildlife habitats. Such impacts will be localized and of short duration.
No short-term impacts on agriculture are expected from in-river containment
of hot spots.
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Maintenance Dredging and Navigation
Barges, boats and other equipment needed in construction activities will
create a hinderance to normal traffic on the river. Siltation and erosion
patterns in the river will be altered in the vicinity of the contained area.
Placement of containment structures could hinder navigation on the river.
IB. Long-term Primary Impacts
Public Health
In the long term, in-river containment will stabilize hot spots and prevent
erosion of PCB-contaminated sediments. In-river containment will also minimize
the release of contaminated material from ice rafting. Decreases in PCB releases
will decrease the health risks associated with PCB-contamination of the Hudson
River. However, health risks could reoccur if containment of hot spots fails.
Major damage to containment structures could occur from high flow periods,
ice jams, or boat collisions. Gradual weakening of containment structures could
arise from normal, long-term river processes.
Fisheries and Aquatic Biota
In-river containment will benefit the fisheries in the long-term because it
will decrease the amount of PCBs readily available for uptake in aquatic eco-
systems. This could help to reduce the PCB content of fish to levels below th$
acceptable tolerance limit. A failure of the containment structures, however,
would cause the release of PCBs to the aquatic ecosystem.
In-river containment will have long-term impacts on contained wetlands.
Silt transported in runoff from the land will accumulate in the contained areas,
covering PCB-laden sediments. This will have the beneficial impact of stabi-
lizing the contained area and encouraging the growth of more deeply rooted
vegetation. This process will further stabilize the hot spot and decrease
volatilization of PCBs.
Containment of wetland hot spots will substantially alter drainage patterns
within the wetland. This may have adverse effects on the nature of the vege-
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tation and wildlife habitat. Containment will reduce the exchange of water,
causing greater extremes in temperature of contained surface waters. Reduced
circulation will also decrease oxygen levels of contained surface waters, par-
ticularly during warm weather. The value of the wetland as a wildlife habitat
will probably decrease.
Containment, stabilization and backfilling of presently shallow hot spots
may create additional wetlands. This would have the beneficial impact of creat-
ing new wildlife habitats in the river system.
Agriculture and Terrestrial Biota
In-river containment will reduce volatilization of PCBs and therefore
reduce the amount of PCBs availabe for uptake by terrestrial ecosystems. This
beneficial impact, however, may not be large because only a small number of hot
spots are suitable for in-river containment under the full-scale project.
Maintenance Dredging and Navigation
By stabilizing PCB hot spots, in-river containment will help prevent further
contamination of down-river sediments. This will help prevent PCB levels from
reaching such high levels that dredge spoils from maintenance dredging would
require costly upland containment.
Siltation and erosion patterns in the river would be altered in the vicinity
of the contained area, possibly creating navigational problems. Placement of
containment structures could hinder navigation on the river.
1C. Secondary Impacts
Because in-river containment will help to reduce the release of PCBs from
hot spots to the river system, the in-river containment alternative will have
beneficial effects, with corresponding beneficial secondary impacts, on the
fisheries, maintenance dredging in the upper Hudson River and ocean disposal of
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dredge spoils from the lower Hudson River. Secondary impacts of this alternative
will be similar in nature to those that will occur from removal of hots spots, as
described in section 1.4 of this chapter (full-scale project). The secondary
impacts attributable to in-river containment of hot spots, however, will not be
large because only a small number of hot spots are suitable for in-river con-
tainment .
ID. Unavoidable Adverse Impacts and Steps to be Taken to Mininize
Harm
Unavoidable adverse impacts can be mnimized by implementing the following
measures:
All work on the hot spots should be performed during the dry season,
between May and September. Low rainfall and low flows will minimize
erosion and scouring, and decrease chances of flood flows pccurring
while the work is still incomplete, thus minimizing release of PCB^
to the river.
Only vegetation that poses a direct hindrance or hazard to work on
the hot spots should be removed.
Protective clothing, including respirators, should be provided to all
workers at the site to minimize health risks.
The public should not have access to the hot spots and surrounding
area during the work phase.
Work which generates excessive noise should only be conducted during
normal working hours to minimize disturbance to the public.
Public access to contained hot spots should be discouraged by posting
of warning signs. If feasible, access should be prevented by placement
of fences.
Hot spots should be covered to a height above the 100- or 500-year
flood level to reduce the risk of erosion during major flood events.
However, this would eliminate the wetland character of the hot spot.
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IE. Contingency Plans
Major damage to the containment structures may occur during high flow
periods, ice jams, or boat collisions. If containment structures are damaged,
repair would have to be made immediately. NYSDEC will have the authority to make
arrangements for immediate repairs.
Contingency plans discussed under the full-scale project (section 4,
Chapter 4 ) should also apply under this alternative.
IF. Monitoring
Short-term monitoring should accompany construction of the containment
structures and, consist of air and water sampling. Water sampling for turbidity,
Cs j lead and PCBs should be done at regular intervals downstream of con-
struction activity. Air quality should be sampled everyday at four locations
representing the major compass directions.
Long-term monitoring will consist of periodic water and air sampling.
Water samples should be taken downstream of each in-river contained hot spot and
should be analyzed for PCBs and heavy metals. Samples should be taken once every
two months. Air samples should be taken and analyzed for PCBs. Additionally,
samples of the vegetation should be analyzed for PCB levels once every year.
2. Remnant Deposit Alternatives
After the dam at Fort Edward was removed in 1973, most of the contaminated
sediment originally contained behind the dam that was not transported down-
stream remained as exposed deposits along the river bank at five locations. Of
these five remnant deposit areas only two, deposits 3 and 5, are presently con-
sidered to be a significant source of PCB to the environment. The most highly
contaminated remnant area, 3A, was removed to the new Moreau NYSDOT site in 1978.
2 A. Remnant Deposit No-Action Alternative
2a. Short-term Primary Impacts
Under the no-action remnant deposit alternative, there will not be adverse
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primary impacts because the PCB-contaminated deposits will hot be removed or
contained. No-action would permit the continued release of PCBs from the remnant
deposits. Such PCB releases could present long-term adverse impacts, as de-
scribed below.
The -beneficial primary impacts of no-action include the avoidance of short-
term construction related effects such as noise, truck traffic, and other disrup-
tions to the public.
2b. Secondary Impacts
Public Health
Under the remnant deposit no-action alternative, the main long-term impact
will be the continued release of PCBs to the Hudson River and surrounding air and
the public health risks associated with PCB contamination of the Hudson River.
The amount of PCBs being released from the remnant deposits to the Hudson,
however, has not been adequately determined. There is a substantial flow of
PCBs, 590 to 1315 kg/yr (1300 to 2900 Ibs/yr), in the Hudson River at Rogers
Island (MPI, 1980d). The source of this flow has not been identified, and it has
not been determined to what extent the remnant deposits are contributing to this
flow. As discussed in section II. 2 of Chapter 2, deposits 1,2,3 and 4A are
subject to erosion, especially during high flows. These deposits, however,
contain relatively low levels and small total amounts of PCBs (Tables 2-8a and
2-8b). Remnant deposits 3 and 5 contain high concentrations and substantial
total amounts of PCBs, but remedial measures have been taken to stabilize them.
Under the no-action alternative, the short-term impacts of the remnant deposits
on water quality and public health cannot be fully assessed until the unknown
source of PCBs in the upper Hudson River is determined and the stability of
deposits 3 and 5 is confirmed.
Under the no-action alternative, continued release of PCB through volati-
lization is also a potential health risk. The remnant deposits, especially those
on the east side of the river, are in fairly close proximity to residential
areas. Some of the remnant deposits are accessible by the public, creating an
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additional risk to public health. The health hazards of exposure to PCB in air
are discussed in Appendix A.
A potential long-term impact of the remnant no-action alternative is the
release of large quantities of PCBs if the deposits undergo extensive erosion
during a high flow period, as occurred in 1976. Erosion of deposits 1,2, 4 and
4A is possible during high flows because little or no stabilization measures
have been taken on them. Erosion of these deposits would not have a great impact
because they do not contain large quantities of PCBs. Erosion of deposits 3 and
5 would release substantial quantities of PCB to the Hudson River, causing a
substantial reduction in water quality, increased contamination of fish and other
biota, the formation of new hot spots in downstream areas of deposition, and
risks to public health. The chances of large scale erosion of deposits 3 and 5,
however, are not great because stabilization measures, including rip-rapping,
have been taken.
Fisheries and Aquatic Biota
The continued release of PCBs from remnant deposits could make substantial
amounts of the contaminant available for uptake by the aquatic ecosystem. Such
releases, depending on their magnitude, may be contributing to the PCB contami-
nation of Hudson River fish. The remnant deposit no-action alternative may
lengthen the time required for fish PCB levels to decrease to levels low enough
for the fishery to be reopened.
Agriculture and Terrestrial Biota
Under the remnant deposit no-action alternative, volatilization of PCBs
from the remnant deposits, estimated to be 130 kg (280 Ib), will continue,
causing locally reduced air quality and contamination of adjacent vegetation.
Agricultural products grown within 700 m (2300 ft) of remnant deposits may have
PCB concentrations above background levels. Volatilization from remnant de-
posits represents a route by which PCBs can enter terrestrial ecosystems and
bioaccumulate in exposed organisms.
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Maintenance Dredging and Navigation
The no-action alternative does not provide protection against large-scale
scouring of remnant deposits during future flood events. Such scouring could
lead to the formation of new PCS hot spots in the river, impairing the ability
to dispose of dredge spoils from the upper and lower Hudson River. Large-scale
erosion of remnant deposits with the consequential release of PCBs to the river
could contribute to PCB contamination of downstream sediments. As discussed in
section I.I of Chapter IV (No-Action Alternative), sediments could become
contaminated with PCBs to such an extent that spoils from maintenance dredging
could no longer be disposed of in usual manners, eventually resulting in a
halt to maintenance dredging and closing of some navigational channels. Although
long-term impacts under the no-action remnant deposit alternative would most
likely not be as great as those associated with large-scale movement of hot spot
sediments, they could be significant because of the large quantity of PCBs
presently contained in the remnant deposits.
2c. Secondary Impacts
The no-action remnant deposit alternative may have adverse secondary impacts
similar to those discussed for the no-action alternative (section I.I of this
chapter). The potential large-scale release of PCBs from the remnant deposits to
the Hudson River could have adverse economic impacts associated with the con-
tinued closure of the fisheries, the contamination of downstream water supplies,
and the halting of maintenance dredging. Adverse secondary impacts are less
likely to result from the remnant deposits than from PCB hot spots in the river
because the remnant deposits are more stable and less subject to scour than the
hots spots. In addition, there are less PCBs contained in the remnant deposits
than in all the hot spots.
Volatilization of PCBs from remnant deposits could contaminate nearby
agricultural crops, especially private garden crops, with unacceptable amounts
of PCBs. This would cause an economic loss to farmers or garden owners if their
crops became unmarketable or inedible.
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The no-action remnant deposit alternative would also have secondary impacts
on hydroelectric power generation at Fort Edward. If the NMPC constructed a
surging dam for the generation of electric power at the old Fort Edward dam
site, as the company has proposed, the remnant deposits would be resubmerged,
and release of PCBs to the river would be accelerated. Therefore, the remnant
deposits would have to be removed or effectively stabilized before construction
of the dam. This would represent a possible impediment for development of the
dam and hydroelectric power.
2d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize
Harm
Control of river flow by the Conklingville Dam would prevent scouring of
the remnant deposits during a flood event. As discussed in section I.I of
Chapter IV, the dam has very limited potential for such use.
No other mitigative measures are considered under the remnant deposit
no-action alternative.
2e. Contingency Plans
Contingency plans are necessary if a future flood event causes further
destabilization of remnant deposits and substantial loss of PCBs to the river.
Measures should be taken to re-establish stability and prevent unrestrained
scouring of the deposits, especially deposits 3 and 5, through bank reinforce-
ment and other erosion control measures. Contingency plans must provide for the
protection of public health if scouring of remnant deposits sharply increase PCB
levels in the river. Such an increase poses a potential threat to downstream
fishery resources and public drinking water supplies. The same contingency
plans that apply under the no-action alternative, discussed in section I.I of
Chapter IV, should also apply to the remnant deposit no-action alternative.
2f. Monitoring
Monitoring of PCB levels in water under the remnant deposit no-action
alternative must be conducted so that any changes in the amounts of PCBs flowing
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downstream at Fort Edward can be detected. Such an increase could indicate that
destabilization of remnant deposits has occurred. Monitoring of water PCS
levels must be intensified during and several weeks after any significant high
flow events.
In addition to the monitoring program, a careful sampling program must be
initiated as soon as possible in the upper Hudson River to identify the present-
ly unknown source of PCBs above Fort Edward. Series of water samples should be
taken starting at Rogers Island and extending upstream several miles. Samples
should be taken over a range of seasonal and flow conditions. If PCBs are
entering the river from a fairly concentrated source, such as an undiscovered
landfill, wastewater discharge, or the remnant deposits, PCB levels should
decrease fairly abruptly upstream of the vicinity of the input. Absence of such
a drop in PCB levels would indicate the existence of a source of PCBs further
upriver or non-point sources. Confirmation of whether or not the remnant de-
posits are presently a substantial source of PCB contamination of the Hudson
River is critical for determining the proper course of action for the remnant
deposites and for determining the relative priorities of dredging lower river hot
spots and removing remnant deposits.
Monitoring of PCB levels in air around the remnant deposits and around
residential areas nearest the deposits should also be undertaken. Monitoring
should be done under various seasonal and meteorological conditions so that PCB
levels under worst case conditions can be assessed.
2B. Denial of Access
2a. Short-term Primary Impacts
The denial of access alternative will have impacts related to construction
activities. Because this alternative only involves limited constuction activity
(erection of fences, placement of warning signs and seeding of bare ground),
these impacts should be minor.
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Public Health
The denial of access alternative will impose a slight health risk to
workers implementing the actions of the alternative. Air concentrations of
PCBs at the remnant deposits could be over 1 ug/cu m, the NIOSH 8-hour recom-
mendation, but well below the 500 ug/cu m OSHA standard. The health effects
of exposure to airborne PCBs are discussed in Appendix A.
Materials will have to be trucked to the sites through residential neigh-
borhoods, causing slight disruption to inhabitants. Because the amount of
materials needed is not large, such impacts will be small and for a short
duration. There will be noise impacts from the machinery needed to implant the
fences. Noise impacts should not be great because heavy machinery is not needed
and the duration of activity will be short.
Fisheries and Aquatic Biota
This alternative may have slight impacts on aquatic biota by causing
small releases of PCBs to the Hudson River during the construction phase. The
removal of vegetation in the path of the fence and the digging of a trench and
post holes for emplacement of the fence may increase erosion and cause slight
increases in PCB losses to the river. The increases should not be large enough
to affect fish or other aquatic biota.
Agriculture and Terrestrial Biota
This alternative will have no primary impacts on agriculture. Noise from
construction activities may disturb local fauna.
Maintenance Dredging and Navigation
This alternative will have no short-term primary impacts on maintenance
dredging and navigation.
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2b. Long-term Primary Impacts
The denial of access alternative will have the same adverse long-term
impacts as described for the remnant deposit no-action alternative (section
II.2A of this chapter) because this alternative has no provisions for stabi-
lization or removal of remnant deposit material. The denial of access alter-
native, however, will have an additional beneficial impact on public health.
Public health risks will be slightly reduced because people will no longer have
access to the deposits, thus eliminating direct exposure to the contaminated
material.
2c. Secondary Impacts
The adverse secondary impacts that could occur under this alternative are
the same as those discussed for the remnant deposit no-action alternative
(section II.2A. of this chapter).
2d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize
Harm
Mitigating measures that should be taken to minimize unavoidable adverse
impacts are described below.
Reseeding of all disrupted soils should be undertaken as quickly as
possible to establish a vegetative cover and prevent erosion.
Work should be carried out during the dry season so that chances of
rainfall are minimized, thus decreasing the potential for erosion of
distrubed soils. River flows will also be lowest during the dry season,
thus diminishing chances of flood flows that could easily erode dis-
turbed soils.
Work and trucking of materials should be done during working, daytime
hours as much as possible to minimize inconvenience and disturbance for
nearby residential areas.
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Protective clothing, including respirators, should be provided to
workers on the site to minimize their health risks.
2e. Contingency Plans
Because the denial of access alternative does not stabilize the remnant
deposits, the contingency plans discussed under the remnant-deposit no-action
plan also apply to this alternative. These plans include the restabilization of
the deposits in the event they are scoured by a flood event, and plans to safe-
guard health of the public if enough scouring of deposits and release of PCBs
occur to threaten downriver drinking water supplies and fishery resources.
2f. Monitoring
The monitoring described under the remnant deposit no-action plan should
also be applied to this alternative.
2C. Remnant Deposit In-Place Containment
2a. Short-term Primary Impacts
The in-place containment alternative involves the stabilization of remnant
deposits by placement of an impermeable cover and by reinforcement of the river
bank. The short-term primary impacts are related to construction activities.
Public Health
The in-place containment alternative could expose workers at the work site
to health risks. Air concentrations of PCB at the remnant deposits could exceed
1 ug/cu m, which is the recommended NIOSH 8-hour standard, but will be well below
the 500 ug/cu m OSHA standard. The health effects of exposure to airborne PCBs
are discussed in Appendix A.
Short-term health threats could be imposed on the public if construction
activities cause an increase in releases of PCBs to air or water during the cons-
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truction phase. Such releases should be low and of short duration, so health
effects should be minimal.
Trucking of materials to the remnant deposits will cause severe disruption
of residential areas near the remnant deposits because of the noise, traffic and
air pollution that will result. The transport of materials needed for in-place
containment of deposits 3 and 5 will require 5,000 to 10,000 truck trips, de-
pending on truck capacities (MPI, 1980d). Noise and air pollution created by the
machinery needed at the work sites will also disrupt nearby residents.
In-place containment would also preclude the removal of the contaminated
material which would release significant quantities of PCBs to the air and water
during excavation. Also there would be an increase in the number of truck trips
for removal.
Fisheries and Aquatic Biota
Destruction of vegetation and disruption of soils during the construction
phase could temporarily increase erosion and destabilize river banks, conse-
quently increasing loss of PCBs to the river. The impacts of such PCB losses
to the water should not be large.
Agriculture and Terrestrial Biota
In-place containment of remnant deposits will have no significant short-
term impacts on agriculture. Noise from construction activities may distrub
local fauna. In addition, existing vegetation on and adjacent to the remnant
deposits and the paths of needed access roads will be destroyed.
Maintenance Dredging and Navigation
In-place containment of remnant deposits will have no significant short-
term impacts on maintenance dredging and agriculture.
2b. Long-term Primary Impacts
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Public Health
Stabilization and cover of remnant deposits would decrease public health
risks by reducing volatilization of PCBs to the air and by reducing any present
losses of PCBs to the river. In the long term, however, any failure of the
containment measures could result in releases of PCBs to the environment and a
reoccurrence of public health risks. Health effects of exposure to PCBs to the
public are discussed in Appendix A. Because PCBs are not removed from the river
system under this alternative, any long-term erosional patterns of the river
could weaken containment measures and cause PCB contamination of the river.
Continuous maintenance of the cover and bank reinforcements would be necessary to
minimize this threat.
Fisheries and Aquatic Biota
In-place containment of the remnant deposits would decrease risks to the
fisheries by reducing PCB losses to the Hudson River by erosion and other pro-
cesses. However, if containment of remnant deposits failed and PCB-contami-
nated sediments were released to the river, risks to the fishery would reoccur.
Maintenance Dredging and Terrestrial Biota
Containment of remnant deposits will decrease the amounts of PCBs entering
sediments of the Hudson River. This would partially prevent dredge spoils
resulting from maintenance dredging of the upper Hudson River from becoming too
contaminated with PCBs to be disposed of in usual manners. The chances of lower
Hudson River sediments becoming too contaminated for ocean disposal also may be
reduced.
2c. Secondary Impacts
In-place containment of remnant deposits will reduce PCB contamination of
the Hudson River, and help to avoid the adverse secondary impacts that could
arise from the continued closure of the fisheries, the halting of maintenance
dredging and the ocean disposal of dredge spoils, and the contamination of
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downstream drinking water supplies, as discussed under the remnant deposit
no-action alternative (section II.2A of this chapter). In-place containment of
remnant deposits, however, may not adequately stabilize the deposits if a surging
dam is constructed at Fort Edward. The costs of additional stabilization methods
or removal of the deposits could be an impediment to development of the dam and
hydroelectric power at Fort Edward.
2d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize
Harm
Unavoidable adverse impacts can be minimized by implementing the following
measures for the in-place containment of remnant deposits:
To control erosion, all work on the remnant deposits should be performed
during the dry season, between May and September. Low rainfall and low
flows will minimize erosion of disturbed soils and decrease chances of
flood flows occurring while the work is still incomplete, thus minimizing
release of PCBs to the river. Disturbed soils should be reseeded as
quickly as possible to stabilize soils and prevent erosion. Only vegeta-
tion that poses a direct hindrance or hazard to work on the remnant
deposits and access roads should be removed.
To minimize the risk of eroding the remnant deposits during floods, the
cover should be brought to a grade level above either the 100 or 500-year
flood level.
Protective clothing, including respirators, should be provided to all
workers at the site to minimize health risks for them.
The public should not have access to the remnant deposits during the
work phase.
To reduce noise impacts, mufflers and engines should be properly main-
tained to minimize noise levels, with the use of additional mufflers,
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silencers, and/or baffle structures as necessary. Work performed near
homes which generates especially loud noise should be scheduled within
normal working hours. Night work should be minimized to the greatest
extent possible (MPI, 1980d).
The contractor should not wash vehicles, change engine oil, or repair
hydraulic lines near the working area or the river. Petroleum compounds
must not leak into the deposit areas or directly into the river because
such compounds will desorb PCBs from debris and sediments. In addition,
all vehicles should be well maintained to minimize exhaust emissions
(MPI, 1980d).
Trucks enroute to the work area carrying uncontaminated sediments should
have their cargo covered, as required by Section 380-a, Chapter 418 of
the Laws of 1975, and 17 NYCRR Part 158 (MPI, 1980d).
Paved roads used by construction traffic should be kept in a broom-
cleaned condition to minimize wind-blown dust. If fugitive dust becomes
a problem at remnant deposits or access roads, a light spray of water or
other appropriate agent should be applied (MPI, 1980d).
Signs, warning lights and/or flagmen should be employed along routes
where heavy truck traffic is anticipated, particularly at busy inter-
sections. Roads which are damaged by truck activity should be repaired
to at least their original condition (MPI, 1980d).
When the project has been completed, the area should be landscaped,
including the planting of trees, to make the area visually attractive.
2e. Contingency Plans
A contingency plan must be established to re-stabilize the remnant deposits
if containment measures fail. If a flood event erodes the capping layer on a
remnant deposit and PCB-laden sediments begin to escape to the river, measures
must be taken as soon as possible to repair the situation.
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There must also be contingency plans to safeguard public health if contain-
ment does fail and large quantities of remnant deposit materials are washed into
the Hudson River during a flood or other unusual event. Measures would have to
be taken to ensure the public would be protected from increases of PCB levels in
downstream areas of the Hudson River. Contingency plans similar to those
discussed for the remnant deposit no-action alternative (section II.2A, Chapter
4 ) would be required.
2f. Monitoring
Under the in-place containment alternative, PCB levels in water downstream
of the remnant deposits will have to be monitored. PCB levels will have to be
monitored frequently in areas several hundred yards downstream of the remnant
deposits when construction is in process to ensure that the activity does not
cause a significant release of PCBs to the river. Levels of PCBs in the air
should also be monitored at the worksite and also in nearby residential areas to
ensure that PCB levels do not increase above acceptable levels while the work is
in process.
Long-term monitoring of PCB levels in the water downstream of the remnant
deposits and in vegetation adjacent to remnant deposits is necessary to make
certain that containment is effective.
2D. Remnant Deposit Complete and Partial Removal
A complete or partial removal of remnant deposits will mainly have short-
term primary impacts directly related to the excavation and hauling away of
remnant deposit material. Complete and partial removal alternatives would have
similar impacts. Complete removal would have impacts of greater magnitude and
longer duration. The long-term impacts of remnant deposit removal are bene-
ficial.
Under the complete removal alternative, 290,000 cu m (380,000 cu yds) of
remnant deposit material would have to be removed, requiring approximately
40,000 truck trips, as discussed in Section II.2 of Chapter 2 . Removal of
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deposits 3 and 5, as proposed by NYSDEC, would involve 56,000 cu m (73,400 cu
yd) and 7,400 truck trips (MPI, 1980d).
Under partial removal plans, remnant deposits which are not removed could
be contained in-place as described in section II.2 of Chapter 2. Impacts of in-
place containment of remnant deposits are discussed in section II.2 of Chapter 4.
2a. Short-term Primary Impacts
Pubic Health
Removal of remnant deposits will have adverse short-term impacts on public
health.
During the removal process, health risks will be imposed on workers. Ex-
cavating the deposits will temporarily increase volatilization and levels of PCB
in the air at and around the work site. Air concentrations of PCBs could be
over 1 ug/cu m, the NIOSH 8-hour recommendation, but well below the 500 ug/cu m
OSHA standard (MPI, 1980d). The health effects of exposure to airborne PCBs are
discussed in Appendix A.
Excavation of remnant deposits will increase volatilizatin of PCBs, in-
creasing contamination of surrounding vegetation and imposing health risks
on nearby residents. During dry or windy conditions, PCB-laden particles will be
lost to the air.
The earth moving equipment will create substantial noise pollution and
contribute to local air pollution in nearby residential areas.
Noise, traffic congestion and air pollution resulting from the large number
of truck trips needed to remove contaminated material will severely disrupt
residential areas in Fort Edward. Trucking of contaminated materials away from
the remnant deposits creates the potential for contamination of roads and road-
side areas if proper containment procedures are not followed on every truck trip.
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The public health implications of upland disposal of PCB contaminated
materials are discussed in section II.4 of this chapter.
Removal of the remnant deposit material nearest the river will result
in resuspension of PCB-contaminated materials and their loss to the river.
Destruction of vegetation and disruption of soils at and around the remnant
deposits will temporarily increase erosion of PCB-contaminated material into the
river. Such releases of PCBs to the river will be small and of short duration,
and impacts on the fish and other aquatic biota should be minimal.
Agriculture and Terrestrial Biota
Vegetation at and adjacent to the remnant deposits and the paths of needed
access roads will be destroyed. Noise from trucks and escavation equipment will
disturb fauna in the vicinity of the remnant deposits and trucking routes.
Increased volatilization of PCBs during escavation may slightly increase con-
tamination of adjacent vegetation. Removal of remnant deposits will not have
significant short-term impacts on agriculture.
Maintenance Dredging and Navigation
Removal of the remnant deposits will have no significant short-term impacts
on maintenance dredging and navigation.
2b. Long-term Primary Impacts
Public Health
Removal of remnant deposits will have beneficial long-term impacts. Re-
moval will significantly decrease potential health threats by stopping PCB
losses from the deposits to the air and river. This will be especially signi-
ficant if the remnant deposits are the presently unidentified source of PCBs in
the Hudson River. The public health risks of exposure to PCBs in water, food and
air are discussed in Appendix A. Removal of remnant deposits will also eliminate
the chance that future erosion, particularly during a flood event, could release
large quantities of contaminated remnant deposit material to the river.
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Fisheries and Aquatic Biota
Removal of remnant deposits will reduce the amount of PCBs entering the
Hudson River. Removal will also eliminate the chance that future erosion
during a flood event could release large quantities of PCBs to the river.
Elimination of this source of PCBs will partially reduce PCB-contamination of
Hudson River fish.
Agriculture and Terrestrial Biota
Removal of remnant deposits will substantially reduce volatilization of
PCBs and therefore reduce contamination of nearby vegetation, including agri-
cultural crops. This will eliminate a possible pathway for PCBs to enter
terrestrial food chains and bioaccumulate in terrestrial fauna.
Maintenance Dredging and Navigation
The beneficial impact of remnant site removal will be the elimination
of this particular source of PCBs as a potential constraint on dredging and
disposal should these deposits be scoured during a flood and transported down-
river.
2c. Secondary Impacts
Removal of remnant deposits will reduce existing and future PCB releases to
the Hudson River, and help to avoid the adverse secondary impacts that could
arise from the continued closure of the fisheries, the halting of maintenance
dredging and ocean disposal of dredge spoils, and the contamination of downstream
drinking water supplies, as discussed for the remnant deposit no-action alter-
native (section II.2A of this chapter). Under the removal alternatives, the
remnant deposits will no longer represent a possible impediment to the construction
of a hydroelectric dam at Fort Edward.
2d. Unavoidable Adverse Impacts and Steps to be Taken to Minimize
Harm
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Unavoidable adverse impacts can be minimized by implementing the same
measures discussed for the remnant deposit in-place containment alternative
(section II.2c of this chapter). The following measures should also be taken
under this alternative:
Excavation should be done by highly experienced personnel so that the
deposits can be removed as quickly, efficiently, and neatly as possible.
This will help to reduce risks of any unnecessary losses of contaminants
to the air or river.
To prevent loss of material to the river, escavation should begin in the
center of the deposit, leaving an outer perimeter of material to act as a
protective earthen dike. Should floating solids result from dredging, a
floating boom would be employed downstream from the dredge site (MPI,
1980d).
Trucks enroute to the disposal area should have their cargo covered, as
required by Section 380-a, Chapter 418 of the Laws of 1975, and 17 NYCRR
Part 158 (MPI, 1980d). It is imperative that the trucks strictly adhere
to the regulations and that they be tightly covered. It is also impor-
tant that they not be overloaded. In addition, the trucks should be
cleaned before leaving the containment site to minimize the tracking of
contaminated material onto the roadways and into the residential areas.
Completely contained trucks or trailers could be useful if there is the
risk of contaminated water running off trucks transporting wet sediment.
The NYSDOH and local authorities, in conjunction with NYSDEC, must
carefully oversee all operations of this alternative, particularly the
trucking of the contaminated material, to safeguard the safety of the
public and workers. State or local police should also be on site and
frequently inspect the trucks involved to make sure that they meet motor
vehicle safety requirements.
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2e. Contingency Plans
Contingency plans must provide for public safety in the event that the
removal operation causes unacceptably high losses of PCBs to the air or river.
Cessation or revision of the operation and evacuation of local residents could be
necessary. Contingency plans regarding downstream drinking water supplies in
the event of additional PCB contamination of the river could also apply.
2f. Monitoring
Throughout the removal operation, PCB levels downstream of the operation
must be frequently monitored so that any significant increase in PCB losses to
the river can be detected. Two sampling wells should be installed near each
downstream perimeter of the remnant deposit to monitor the movement of PCBs with
groundwater through the deposits and into the water column (MPI, 1980d). PCB
levels in the air at the worksite and in adjacent residential areas must also be
monitored.
After the removal operation is complete, PCB levels in the river downstream
of the former remnant deposits must also be monitored to ensure that substantial
amounts of contaminated deposits were not left behind. Such deposits could
continue to release PCBs to the river.
3. In-River Dredging Mechanisms
This section of the EIS will discuss the primary environmental impacts of
the feasible dredging alternatives available for physically removing PCB contam-
inated sediments from the Hudson River. In-river dredging mechanisms are
components of the full-scale and reduced-scale projects. As a result of exces-
sive costs and other technical considerations, mechanical unloading of dredge
spoils and dredging systems discussed under "Other Dredging Systems" in chapter
2, except for the mud cat, were found to be infeasible and will not be considered
further. The mud cat might have limited application in shallow hot spots.
Hydraulic dredging and transport, and clamshell dredging with hydraulic
pumpout and unloading are the main feasible alternatives, and they will be
evaluated for potential adverse and beneficial, short-term environmental impacts.
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Environmental analysis of the dredging and transport mechanisms will be discussed
as they affect the major primary assessment objectives outlined at the beginning
of this chapter with special emphasis on the following parameters:
« Water Quality
Public Health
Fisheries and Aquatic Biota
Maintenance Dredging and Navigation
The long-term primary impacts and secondary impacts of the full-scale and
reduced-scale projects, which include in-river dredging components, in-river
containment and remnant deposit alternative components, have already been
discussed in Sections 1.4 and 1.5 of this Chapter.
3A. Short-Term Primary Impacts
3a. Hydraulic Dredging
Water Quality
The most critical environmental factor that may be affected by dredging
activities is water quality. The impacts are a result of (1) continued effects
of PCBs left in place after dredging; (2) PCBs lost downriver in the dredge plume;
and (3) PCBs recycled to the river in the return water. The magnitude of these
losses, as projected by MPI (1980d), are summarized in Table E-3 (Appendix E).
PCB losses to the water column from a hydraulic dredgehead occur when
bottom material disturbed by the rotating and laterally moving dredgehead is
stirred up but is not drawn into the hydraulic pipeline. MPI (1978b, 1980d)
estimates, based on the assumption that the bed material is predominantly sand
and gravel, that 2 percent of the total material dredged will escape to the
water column. Laboratory testing conducted by MPI demonstrated that in a
suspension approximating a dredge plume, about 20 percent of the PCB does not
readily resettle, while the remaining 80 percent would settle downstream from
the dredge. The suspended PCB contaminated sediment may or may not resettle in
downstream hot spots and it is possible that 100 percent of the plume could be
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lost (MPI, 1980d). If a flow of 85 cu m/s (3,000 cfs) is assumed, the estimated
average PCB increase above ambient levels immediately downstream of the dredge-
head could be 0.2 ug/1 (ppb) for the hydraulic dredge. The NYSDEC standard for
ambient levels of PCB downstream from a dredging operation is 0.5 ug/1 (ppb)
(MPI, 1978a). Dredgehead losses from the hydraulic dredge alternative are within
this standard (MPI, 1978a). If this standard were exceeded, dredging operations
would be stopped.
Tofflemire (1979) evaluated the dredgehead losses from a hydraulic dredge
and clamshell dredge operating adjacent to each other. The objective was to try
to compare the two types of dredging where all variables were equal. He at-
tempted to relate suspended solids, turbidity and PCB losses from the dredge
plume. Readings taken 60 m (200 ft) downstream of the hydraulic dredge indi-
cate very little turbidity and little increase in PCB concentrations in the
water column. However the transmissometer used to measure turbidity malfunc-
tioned and there was difficulty in establishing a correlation between suspended
solids and turbidity. Though these problems may have altered the data, the
overall conclusion that a dredge plume developed by the hydraulic dredgehead
will disperse and resettle within 1.6 km (1 mi) downstream is valid. However,
both background levels and anticipated increases are several orders of magnitude
above the EPA criterion for the protection of freshwater life, which is 1 part
per trillion or 0.001 ug/1 (MPI, 1978a).
In addition to loss of PCEs in the dredgehead plume, certain amounts will
be missed during dredging, due to inherent imprecision in dredge positioning,
depth control, and difficulties with obstructions in the river. MPI (1978a,
1980d) estimates that a hydraulic dredge would miss 2 percent of the hot spot
material. This includes a dredging pay limit set at 91 cm (36 in.). Based on
the 2 percent loss, it is estimated that 950 kg (2,100 Ibs) will be left in the
Thompson Island Pool. However, this estimate for PCBs missed during dredging
may be low. Tofflemire (1979) estimates that hydraulic dredging of PCB hot
spots consisting of sediments whose grain size composition averages between 50
to 60 percent silt, will miss 13 percent of the sediments. Factors critical to
control of contaminated layer removal are boom swing speed, position of the
dredge, amount of overlap, despth of dredge cut, and operator experience.
Further evaluation of dredgehead placement and the amount of PCB contaminated
material missed by the dredgehead is necessary before a full evaluation of
impacts is possible.
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Under the hydraulic dredging alternative, the average return water flow
will be 37,800 cu m/d (10 mgd). This water is mixed with the dredged material at
the dredgehead and used to transport the sediments by pipeline to the contain-
ment site. At the containment site, the sediment and water will flow through a
series of settling lagoons to produce a nearly sediment-free water. At this
point it will enter a water treatment plant to remove suspended particulates
with PCBs. The plant will have a capacity of 49,200 cu m/d (13 mgd) and
consist of coagulation, flocculation, and sedimentation units. For hydraulic
dredging of the Thompson Island Pool, an estimated 70 kg (160 Ibs) of PCBs would
be lost via the return flow per year. Such a loss would result in an increase
above ambient of 0.1 ug/1 (ppb), assuming complete dilution of the effluent in 85
cu m/s (3,000 cfs). As estimated previously, dredgehead losses would raise the
ambient PCB levels of 0.2 ug/1 (ppb). The total calculated PCB increase attribut-
able to the hydraulic dredge, without carbon absorption, would be 0.3 ug/1 (ppb)
(MPI, 1980d). This increase would occur during the 20-hour work day. Background
levels measured at Schuylerville and Stillwater during low flow between June and
September 1977 averaged approximately 0.7 ug/1 (ppb). While this average may be
atypically high, it will be used here as a worst case (MPI, 1978a). The esti-
mated PCB increase in combination with the background level would result in a
total of PCB concentration of approximately 1.0 ug/1 (ppb).
The potential loss of heavy metals to the water column from dredgehead
disturbance of the bottom and return flow concentrations is important due to the
toxicity of many metals to aquatic life and the effect on down river public water
supplies. Such losses are dependent on the efficiency of the dredge, the metal
levels encountered in bed materials (Table E-4, Appendix E) and the ability of
the return water treatment process in removing metals along with the PCBs. The
majority of heavy metals in the upper Hudson River are bound to the organic and
fine grained particulate matter. Additionally, metals may also be present in
the interstitial water or as part of the crystalline structure. Upon disturbance
from the dredgehead, the interstitial component is immediately released to the
water columns, while the fraction that is attached to the particulate matter
releases to the water column at various rates, depending upon ambient conditions
such as pH, redox potential, and the presence of complexing chemicals which
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would act to precipitate dissolved metals. Because of the diversity of factors
affecting the release of heavy metals, it is highly difficult to predict water
column interactions (MPI, 1978a). However, a conservative best-estimate is
possible based on bed material concentrations.
MPI (1978a) has estimated dredgehead losses for hydraulic and clamshell
dredging. Using existing information for the Thompson Island Pool, assumptions
regarding the position of elevated metal levels in the sediment column and data
on settling rates gathered from jar tests, an initial increase above ambient was
determined from dredgehead losses (Table E-5, Appendix E). Ambient heavy metal
values at Waterford between April 1975 and July 1976 were used.
As Table E-5, (Appendix E) indicates, for the majority of heavy metals,
neither dredging alternatives will create a significant increase. However,
background concentrations in lead are frequently three to ten times higher than
NYSDEC dredging certification standards and suspension of lead concentrated
riverbed materials may cause significant increases in lead levels adjacent to
the dredgehead. Mercury levels in the river bed sediment were small, but
background levels are high when compared to the NYSDEC standard. This metal
requires monitoring during dredging due to its high toxicity.
To a large degree, heavy metal losses at the dredgehead are based on dredge
plume losses for hydraulic (2 percent) and clamshell (4 percent). Subsequently,
heavy metal loss rates for the clamshell dredgehead are expected to be greater than
hydraulic dredgehead. While most increases in heavy metals will be minor, lead
and mercury increases will be significant.
In addition to dredgehead losses, heavy metals will be added to the water
column from the return flow. The treatment process proposed for the return water
is coagulation and sedimentation. It is difficult to estimate the heavy metal
losses, but a rough approximation can be made based on jar tests of sediment
samples collected from the Thompson Island Pool, Buoy 214 and Route 4 Bridge at
Northcumberland. With the exception of cadmium, heavy metal levels in the
unfiltered supernatant were within NYSDEC standards. The high cadmium concentra-
tions may reflect a greater tendency for cadmium to desorb from sediments into
the water.
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Using the NYSDEC standard as a worst case situation, MPI (1978a) has
estimated the return flow increases over the ambient metal levels in the upper
Hudson River. Table E-6, (Appendix E) summarizes these increases and the dredge-
head increases discussed earlier. Because hydraulic dredging return flow is
larger than clamshell, relative increases in heavy metals are an order of magni-
tude higher. However, all of the anticipated heavy metal increases, with the
possible exception of cadmium, are within the previously established NYSDEC
certification standards. In combination with background heavy metal levels,
however, the levels may equal or exceed the standards, particularly for cad-
mium, lead and mercury (MPI, 1978a).
Public Health
NYSDEC has determined that the plume caused by resuspension of river
sediments will extend up to 1.6 km (1.0 mi) downstream of the dredging acti-
vity. The nearest water supply intake (for Stillwater) would be located 3.2 km
(2.0 mi) downstream from the nearest dredging operations (at hot spot 36). The
water supply intake for Waterford would be located 12.1 km (7.5 mi) downstream
from the nearest dredging operations (at hot spot 40).
The draft SEQRA EIS (MPI, 1980d) reports:
In the Thompson Island Pool, total PCB increases above ambient are
estimated as: hydraulic dredge 0.3 ug/1; clamshell dredge, hydraulic
pumpout with recycle 0.7 ug/1; clamshell dredge, hydraulic pumpout
without recycle 0.8 ug/1. These estimates are based on the following
assumptions: 3,000 cfs [85 cu m/s] river flow; 114 day project period
for the hydraulic dredge, 81 days for the clamshell; and PCB loss rates
as discussed previously. Recent background levels for comparable flows
at Schuylerville and Stillwater range from 0.5 to 1.0 ug/1 [Tofflemire
and Quinn, 1979],
Clamshell dredging would be employed exclusively below the Thompson
Island Dam. The ambient PCB increases shown for the Thompson Island
Pool represent a "worst case", in that the estimated overall sediment
PCB concentrations in the lower pools are approximately one-half that
of the Thompson Island Pool (45 ug/g versus 96 ug/g including over-
cut). River flows average water column PCB increases for clamshell
dredging below Thompson Island should be comparable to hydraulic
dredging in the Thompson Island Pool.
Therefore, under the worst case scenario, dissolved PCB levels would
increase by 0.8 ug/1 (ppb) immediately downstream from the dredging operation
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at the Thompson Island Pool. The resulting ambient concentrations of PCBs at
Stillwater could possibly increase during the dredging operations. The NYSDOH
recommended guidelines for short-term exposure to PCBs in drinking water is 1.0
ug/1 (ppb).
Dredging of hot spots, particularly those in shallow water, will increase
PCB concentrations in the air. Health risks will be greatest for workers
involved in the dredging operation. Air concentrations of PCBs could exceed the
recommended NIOSH 8-hour standard of 1 ug/cu m but will probably be well below
the 500 ug/cu m OSHA standard. PCB air levels at homes in the vicinity of
hot spots being dredged will also be elevated, but such increases are not
expected to exceed safe levels. Noise levels of the hydraulic dredge will be
fairly constant, but not particularly high. Dredging operations will probably
continue for 24 hours a day. People living near the river will be affected,
especially at night.
Fisheries and Aquatic Biota
Impacts on biota from dredging operations will originate from two sources:
destruction of benthic organisms and their habitat; and reductions in water
quality.
The removal of benthic organisms, which are food sources for fish, will
vary significantly depending on the extent of dredging. While hydraulic or
clamshell dredging will result in a similar disturbance of substrate, the level
of effort for the dredging will dictate the extent of overall disturbance and
loss of habitat. Dredging of all 40 hot spots will disturb eight percent of the
river bottom in the eight pools, while just dredging the hot spots in the
Thompson Island Pool would disturb four percent of the river bottom. Organism
recolonization would be hindered by removal of parent stock and radical alter-
nation of the substrate, but migration from adjacent undisturbed areas should
recolonize the dredged area in one to two seasons after dredging (MPI, 1980d).
Under the full-scale project, hot spots in wetlands will be removed.
Removal of the hot spot will destroy part or all of the wetland, possibly
causing a substantial loss of wildlife habitat, loss of breeding and nursery
areas for fish and other fauna, and alterations of food chain relationships.
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The principal water quality problems which will affect aquatic organisms
are increased levels of PCBs and heavy metals. Although the expected increases
in PCB concentrations from the dredging activities are expected to be below the
acute and chronic toxicity levels of most adult fish, the increases may be
significant to sensitive species (MPI, 1978a). For example, spawning of the
fathead minnow, a species known to inhabit the upper Hudson River, is affected by
Aroclor 1242 at levels as low as 1.8 ug/1 (ppb) (USEPA, 1976a). The hydraulic
dredge in combination with background levels could equal or exceed this level
(MPI, 1978a).
Increases in PCB levels in the water will increase PCB levels in exposed
fish. The amount of increase would depend on the fraction of entrained, bio-
logically active PCBs which is capable of moving across fish gill membranes.
After dredging is complete and entrainment ceases, some of the bioconcentrated
increment would be metabolized. However, the more chlorinated hydrocarbons are
resistant to such breakdown. The impact of the PCBs on fish would be reduced
with distance downstream (MPI, 1978a).
The estimated increases in heavy metals, particularly cadmium and lead, may
have adverse effects on certain sensitive fish species. For soft waters such as
the upper Hudson River where dredging will occur, the EPA recommended criteria
for cadmium are 0.4 ug/1 (ppb) for cladocerans and salmonids, and 4.0 ug/1 (ppb)
for other aquatic forms (MPI, 1978a).
Lead background levels as high as 300 ug/1 (ppb) have been measured at
Waterford. Where lead levels are high in the bottom material, dredge-related
entrainment could augment the background levels and aggravate existing adverse
conditions (MPI, 1978a). .
Similarly, background mercury levels approach or exceed the EPA creterion of
0.05 ug/1 (ppb) for aquatic life. Increases against this background are not
large but could exceed threshold values under existing conditions (MPI, 1978a).
Suspended solids may cause sublethal effects on foraging ability and res-
piration of fish immediately within the plume. Because of their mobility, how-
ever, fish can avoid such turbid areas. Dredging conducted during the months of
April and May would interfere with spawning, at least immediately downstream
from the dredge (MPI, 1978a).
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Invertebrates could also be affected by increases in PCBs and heavy metals
in the river during dredge operations. Invertebrate populations immediately
downstream from the dredge site could encounter increases in ambient PCBs de-
monstrated to be toxic in laboratory experiments. For example, a three-week
exposure to 1.3 ug/1 (ppb) Aroclor 1254 was observed to cause 50 percent mor-
tality in populations of the water flea Daphnia (MPI, 1978a). It should be noted
that benthic and planktonic organisms in the upper Hudson River already inhabit a
highly contaminated environment, with background PCB levels which occasionally
exceed 1 ug/1 (ppb) (MPI, 1980a).
The invertebrate situation with regard to heavy metals is similar to that
of the fishery. Increases in cadmium could exceed the tolerance range of sen-
sitive species. Increases in mercury and lead may not be substantial, but
may have significant effects in combination with high background levels.
Increases in PCB and heavy metals in aquatic organisms would be transferred via
the food chain to waterfowl and other organisms of higher trophic levels (MPI,
1978a).
Agriculture and Terrestrial Biota
Dredging of hot spots, particularly those in shallow water, will increase
PCB contamination in the air, causing increased contamination of nearby ter-
restrial vegetation. Such contamination will be localized and at low levels.
Operation of the dredge equipment and resulting noise will temporarily
disrupt nearby wildlife habitats and possibly interfere with feeding, breeding
and nesting.
Hyduraulic dredging will not have any significant short-term impacts on
agriculture.
Maintenance Dredging and Navigation
Dredging activities will have adverse short-term effects on navigation in
the river. Floating pipelines, and other dredging apparatus may hamper the
passage of barges and other river traffic. If barges are used to transport
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dredge spoils, they would also block river traffic, especially at the locks.
Each operating dredge would generate four barge trips per day, and each barge
trip would require 30 minutes of lock time (round-trip) in each lock upstream of
dredging operations. Therefore, a single dredge would add two hours of lock time
at each lock daily; two dredges, four hours; three dredges, six hours; and so
forth. Depending on the amount of river traffic, these increases may result in
occasional delays (MPI, 1978a).
3b. Clamshell Dredging
Water Quality
The clamshell dredging operation loses sediment during the raising and
lowering of the bucket. The greater the water depth, the more sediment is
lost from the bucket. Additionally, it is difficult, but not impossible, for the
operator to overlap each bite of the bucket, resulting in a bottom with mounds
and holes. However, this can be minimized by careful positioning of the clam-
shell bucket during operation.
MPI (1978a) estimated dredgehead losses from a clamshell dredge to be 4
percent of the total material dredged. This is twice the material lost from the
hydraulic dredge. If relative rates of removal are considered, then total losses
for the clamshell dredging will be 1.5 times greater than the hydraulic dredge.
Monitoring of side-by-side operation of a clamshell and hydraulic dredge in-
dicates that the clamshell tends to suspend more material than the hydraulic
dredgehead (Tofflemire and others, 1979). However, problems developed with the
testing equipment, as discussed under the previous section. Assuming that the
amount of material to be dredged from the Thompson Island Pool is 840,000 cu m
(1.1 million cu yd) and the average PCB concentration in this material is 50
ug/g (ppm), MPI (1978a) has estimated that the total amount of PCBs lost to the
water column from the dredgehead is 235 kg (520 Ibs). If an average flow of 85
cu m/s (3,000 cfs) is assumed, the estimated average PCB increase above ambient
levels immediately downstream from the dredgehead is 0.4 ug/1 (ppm). These
increases would occur over a 20-hour work day.
Because clamshell dredging will cause a larger dredge plume than hydraulic
dredging, it will also suspend more heavy metals at the dredgehead (Table
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E-5, Appendix E). However, return flow for clamshell dredging is less than
hydraulic, producing less total loading of heavy metals to the river. Based on
estimates which include loss from the dredgehead and return flow, clamshell
dredging appears to minimize heavy metal losses to the water column in comparison
to the hydraulic dredge. However, the return flow concentrations were not
empirically determined and may bias the calculations against the hydraulic
dredge. It is therefore not: possible to favor conclusively either dredging
alternative with respect to heavy metals (MPI, 1978a).
MPI (1980d) estimates that the clamshell dredge would miss about 4 percent
of the PCB contaminated sediment in the hot spots. However, Tofflemire and
others (1979) estimates that 13 percent of the PCB will be missed during accurate
dredging. This is a large difference and could have significant effects on PCB
desorbtion and water column concentrations. Further investigations are necessary
to evaluate this discrepancy.
The volume of return flow for the clamshell dredging operation will be 20
times less than that for the hydraulic dredge because the water would be
recycled back to the pumpout barge. The estimated increase in PCBs in the upper
Hudson River caused by return water is 0.1 ug/1 (ppm) (MPI, 1978a). The total
increase above ambient level due to the dredge plume and recycling of the pumpout
water is 0.7 ug/1 (ppb) (MPI, 1980d).
Clamshell dredging would be employed exclusively below the Thompson Island
Pool. The ambient PCB increases shown for the Thompson Island Pool represent a
"worst case", in that the estimated overall sediment PCB concentrations in the
lower pools are approximately one-half that of the Thompson Island Pool (45 ug/g
[ppm] versus 96 ug/g [ppm] including overcut). River flows would be higher due
to increased drainage basin area. Hence, average water column PCB increases for
clamshell dredging below Thompson Island should be comparable to hydraulic
dredging in the Thompson Island Pool.
Public Health
The impacts of clamshell dredging on the quality of downstream drinking
water supplies will be similar to those discussed in Section 3a (Hydraulic
Dredging) of this chapter. However, the impact of clamshell dredging may be
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slightly greater because it may result in slightly higher concentrations of
PCBs in the river water.
Air quality effects associated with clamshell dredging will be slightly more
substantial than for the hydraulic system. With the clamshell dredge, excavation
may generate septic odors as the spoil is placed in the receiving barge. In
addition, the agitation caused by the bucket entering and leaving the water
surface, or water draining from the closed bucket may result in the entrainment
of pathogens associated with contaminated sediments in airborn droplets. Vola-
tilization of PCBs will occur when the contaminated material is placed on the
receiving barge and during the towing of the barge to the containment site.
Noise levels from mechanical dredges are slightly higher than those from
hydraulic dredges. In addition there would be noise from the tugs that transport
the barges and the pumpout barge. Operations are scheduled for 24 hours a day
and may effect people living near the river.
Fisheries and Aquatic Biota
The clamshell dredge will have a slightly larger effect on aquatic biota
than the hydraulic dredge. The increased concentrations of PCBs that may occur
downstream from the dredgehead would increase biological PCB uptake within the
areas of the dredge plume. Additionally, heavy metals placed into the water
column by disturbance of river bed material could be incorporated into the food
chain.
As with hydraulic dredging, the full scope clamshell dredging program calls
for removal of hot spots that are wetlands. Removal of such hot spots will
result in the destruction of wetlands and subsequent loss of habitat space.
Additionally, any benthic communities associated with hot spots will be des-
troyed.
Agriculture and Terrestrial Biota
The impacts of clamshell dredging on nearby vegetation will be similar to
those discussed for hydraulic dredging. PCB contamination of vegetation may be
slightly higher with clamshell dredging, however, because more PCBs may be
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volatilized by clamshell dredging than hydraulic dredging. Clamshell dredging
will also create more noise, causing greater disruption of nearby wildlife
habitats.
Clamshell dredging will not have significant short-term impacts on agriculture.
Navigation
Clamshell dredging will have adverse short-term impacts on navigation in the
river. During the removal of hot spots, dredging apparatus may block river
traffic. If barges are used to transport dredge spoils, they would also hamper
river traffic, especially at the locks. Each operating dredge would generate
four barge trips per day, and each barge trip would require 30 minutes of lock
time (round trip) in each lock upstream of dredging operations. Therefore, a
single dredge would add two hours of lock time at each lock daily; two dredges,
four hours, and three dredges, six hours, and so forth. Depending on the amount
of river traffic, these increases may result in occasional delays (MPI, 1978a).
3c. Other Dredging Systems
Various other dredging systems were evaluated in the alternative discus-
sions. Presently the mud cat dredge seems to be the only minor dredging option
that seems feasible for this project.
The mud cat dredge operates by using two augers that loosen and feed the
sediment to a suction pipe located beneath the dredge. The head is 2.5 m (8.0
ft) wide and can take as little as a 0.5 m (1.5 ft) thick cut.
Water quality effects from operation of the mud cat would be similar to the
hydraulic dredge. Because the mud cats would be used for limited work in shallow
areas, effects would be proportional to its use.
3B. Long-term Primary Impacts
The long-term primary impacts associated with the removal of PCBs from the
Hudson River under the full-scale project and reduced-scale project have been
discussed in Sections 1.4 and 1.5 of this chapter.
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3C. Secondary Impacts
The secondary impacts associated with the removal of PCBs from the
Hudson River under the full-scale project and reduced-scale project have
been discussed in Sections 1.4 and 1.5 of this chapter.
3D. Unavoidable Adverse Impacts and Steps to be Taken to Minimize Harm
Unavoidable adverse impacts from the dredging mechanisms are: (a) suspen-
sion of PCB-contaminated material at the dredgehead of the various dredging
units; (2) missed PCB-contaminated material; and (3) PCBs returned to the river in
the return water flow.
Measures to limit adverse environmental effects and maximize the efficiency
of the PCB removal, as given by MPI (1980d), are:
Dredging
Hot Spot DelineationAdditional PCB sediment samples will be taken for
lower pools prior to any remedial dredging to better define the depth
and areal extent of contamination. The existing sediment PCB data base
is accurate enough for planning, but not implementation of a hot spot
dredging program. The data are fairly complete for the upper pools, but
become more intermittent with distance downstream. Additional data are
desirable to define more precisely the hot spots to insure accurate
removal of contaminated material.
SchedulingDredging would take place during the low-flow period between
May 15 and September 15 (or until higher flows resume in the fall) to
minimize downstream PCB losses.
Operation Precautions, Hydraulic DredgePCB losses from the hydraulic
dredge would be minimized by contractual control of the cutter and swing
speed.
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Operation Precautions, Clamshell DredgePCB losses from the clamshell
dredge would be reduced by limiting the hoisting speed through the water
column, and by positioning the dredge and receiving barge so as to
minimize the length of bucket swing above the water.
Hydraulic Dredge ModificationsThe feasibility of placing a shroud over
the top of the cuter in order to increase suction efficiency and limit
the escape of suspended material will be examined carefully.
Clamshell Dredge ModificationsTight seals on the bucket lips will be
required. The feasibility of placing a shroud over the top of the bucket
or completely enclosing the bucket to reduce washout during hoisting will
be assessed in the design phase.
Floating BoomWhen dredging results in a floating scum, a floating boom
would be positioned downstream from the work site. The employment of
such a boom should not impede navigation and would be dependent on
favorable current conditions. The boom would be cleaned at least daily,
and the trapped material placed in the disposal site.
Silt CurtainWhere dredging results in an extensive surface plume a silt
curtain may be required. The curtain would extend from the water surface
to a point midway in the water column.
Marsh RestorationIf it is determined that the benefits of dredging a
particular contaminated marsh hot spot outweigh the adverse impacts of
habitat loss, and one or more wetlands are removed, marsh restoration may
be a feasible mitigating measure. Garbish (1979) has outlined the steps
required for marsh requirement following dredging, which are summarized
below:
Dredged areas filled with uncontaminated sediments to predetermined
above-grade elevation.
Following settling and consolidation, areas filled and/or graded to
final elevation.
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Upstream structures may be required to minimize scour; downstream
silt screens may be needed to minimize sediment loss.
After final grading, nursery grown stock or sprigs from nearby
marshes transplanted, maintained for at least one season.
Garbish (1979) notes that replacement plants must be set out at the same
elevations that pre-existing or nearby plants of the same species are estab-
lished. Avoidance of areas subject to high velocity and scour is necessary in
achieving successful restoration. Garbish reports successful regeneration of
wetlands with Peltandra virginica (arrow arum), Pontederia cordata (pickerel
weed), Sagittaria latifolia (duck potato), Scirpus americanus (American three
square), Typha sp. (cattaila), and Leesia oryzoides (rice cut grass). All of
these species are found in the existing upper Hudson River marshes.
Shoreline ConditionsDuring the dredging design phase detailed field
studies and analyses will be undertaken to minimize interference with
overhanging trees and to avoid river bank instability.
Dredged Material Transport
Hydraulic Dredge PipelineWhere navigation may be impeded it would be
necessary to submerge the pipeline.
Pipeline LeaksWhile small leaks are inevitable, operation would be
stopped immediately if a major leak or a break occurs.
Hydraulic Pumpout of BargesIn order to reduce leakage, welded connec-
tions would be used in the pipeline construction, and a check valve
would be installed at the pumpout station to prevent backflow.
Loading of BargesSufficient freeboard must be maintained inside the
barge to prevent overflow or spillage during transport. Alternatively, a
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splashboard could be installed around the top of the barge, permitting
complete filling and thereby maximizing productivity.
*
3E. Contingency Plans
Monitoring will be ongoing during the dredging operation in order to have
continuous information on the water quality effects resulting from disturbances
of the river bottom. If levels exceed standards, the dredging operation will be
halted.
If PCB and heavy metal concentrations in the water column near public water
supply intakes exceed safe limits additional treatment or alternative water
supplies will be required.
3F. Monitoring
In the design phase, provision of an on-site laboratory for analysis of PCB
samples taken ahead of the dredge will be evaluated. An abbreviated technique
would suffice which should measure total PCBs as being either less or greater
than 50 ug/g (ppm). The extraction technique developed by GE, which has an
approximate turn-around time of 1 hour, will be investigated. Materials which
tend to occur with PCB, such as cesium 137 and lead, could also be monitored.
The distribution of cesium 137,, a nuclear testing fallout product, is closely
correlated with PCB, and the analysis procedure for cesium may be simpler than
that for PCBs. Lead is slightly less closely correlated with PCBs.
Sufficient samples should be taken to document any water quality impact of
hot spot dredging, and to ensure compliance with certification standards estab-
lished by NYSDEC. A minimum program should include sampling for PCBs, lead,
chromium, suspended solids and turbidity.
Monitoring for airborne PCBs should be conducted at the dredge sites.
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Intensive monitoring would be conducted during early phases of excavation or
dredging of materials with high concentrations of PCBs. If air PCB concentra-
tions are acceptable at these areas, monitoring would be reduced during excava-
tion or dredging of less contaminated areas.
4. Containment Site
Disposal of the contaminated dredge spoils by any means other than upland
containment in a secure landfill is considered infeasible at this time. Spoil
biodegradation and physical destruction are not cost-effective when dealing with
the volumes of spoil that will be generated by this project. Other potentially
feasible processes are not yet operational on a large scale. Therefore, the
need for a secure containment facility is an important part of any dredging
alternative for removal of PCB-contaminated sediments from the upper Hudson
River.
4A. Short-Term Primary Impacts
Primary impacts associated with the containment site are the disturbances
caused by construction activities, water quality changes resulting from discharge
to the Hudson River of the return flow, air quality changes resulting from
volatilization of PCBs from the dredge spoil, and effects to groundwater caused
by infiltration of leachate.
Public Health
The protection of public health from volatilization of PCBs of the dredge
spoils during placement of the spoils in the containment facility, discharge of
PCB-contaminated return water to the Hudson River, infiltration of leachate to
the groundwater and disturbance from the construction processes is of paramount
importance in the operation of the proposed project. With the inclusion of
specific mitigating measures outlined in section 4d of this chapter potential
environmental impacts will be minimized.
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In order to comply with the NYSDOH recommendation that PCB concentrations in
the air at residences not exceed 1.0 ug/cu m for any 24-hour period (Appendix I),
mitigating measures may be necessary to reduce volatilization from the site
during placement of the dredge spoils (Appendix J). If the dissolved concentra-
tion of PCBs in the containment area exceeds 28 ug/1 (according to WAPORA), or 43
ug/1 (according to MPI) during the dredging operations, and adverse meteoro-
logical conditions occur as well, then it has been computed that the NYSDOH air
quality recommendation could be violated at the nearest residence (Appendix J).
However, under normal meteorological conditions it is predicted that the NYSDOH
guideline will not be exceeded with any regularity.
However, it has been demonstrated that PCBs do volatilize from the water
column of the Hudson River and from PCB-contaminated sediments in the remnant
deposits and river bed. Tofflemire (1980) has estimated that 1,360 kg/yr (300
Ib /yr) of PCB is presently being released from existing contaminated land fills
and dumpsites in the upper Hudson Basin. Elevated ambient PCB levels have been
observed at several contaminated dumpsites and concentrations exceeding the NIOSH
8-hour recommendation have been recorded at dumpsites in the Fort Edward and
Glens Falls areas.
Additionally, the BTI (1978) sampled plants near the Fort Miller dumpsite in
order to determine a relationship between foliar PCB levels and distance from a
source of PCB volatilization. From their sampling program at the Fort Miller
dumpsite and PCB contaminated dredge spoil disposal sites they determined the
following:
At the Fort Miller dumpsite elevated foliar PCB levels were obtained at
distances as far as 700 m (2300) ft from the dump.
Measurable increases in foliar PCB levels were apparent within 100 m
(330 ft) of the Buoy 212 dredge spoil disposal site.
Elevated foliar PCB levels were apparent within 200 m (640 ft) of the old
Moreau dredge spoil disposal site and are expected to approach the
limits of detection (i.e. undistinguishable from background levels) as
far as 300 m (980 ft) from the site.
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These examples illustrate the volatile nature of PCBs and the potential environ-
mental effects from atmospheric losses while the dredge spoils are being placed
in the containment site.
Under the hydraulic-dredging alternative, the average return water flow will
be 3,780 cu m/d(10 mgd). This water is mixed with the dredged material at the
dredgehead and used to transport the sediments by pipeline to the containment
site. At the containment site, the sediment and water will flow through a series
of settling lagoons to produce a nearly sediment-free water. At this point it
will enter a water treatment plant to remove suspended particulates with PCBs.
The plant will have a capacity of 49,200 cu m/d (13 mgd) and consist of coagu-
lation, flocculation and sedimentation units. For hydraulic dredging of the
Thompson Island Pool, an estimated 70 kg (160 Ib) of PCBs would be lost via the
return flow per year. Such a loss would result in an increase above ambient of
0.1 ug/1 (ppb), assuming complete dilution of the effluent in 85 cu m/s (3,000
cfs).
In addition to heavy metal dredgehead losses, heavy metals will be added to
the water column from the return flow. The treatment process proposed for the
return water is coagulation and sedimentation. It is difficult to estimate the
heavy metal losses that will occur, but rough approximation can be made based on
jar tests of sediment samples collected from the Thompson Island Pool, Buoy 214
and Route 4 Bridge at Northcumberland. With the exception of cadmium, heavy metal
levels in the unfiltered supernatant were within NYSDEC standards. The high
cadmium concentrations may reflect a greater tendency for cadmium to desorb from
sediments into the water compared to other heavy metals.
Using the NYSDEC standard as a worst case situtation, MPI (1978a) has
estimated the return flow increases over the ambient metal levels in the upper
Hudson River. Table E-5 (Appendix E) summarizes these increases and the dredge-
head increases discussed earlier. Because hydraulic dredging return flow is
larger than that for clamshell dredging, relative increases in heavy metals are
an order of magnitude higher. However, all of the anticipated heavy metal
increases, with the possible exception of cadmium, are within the previously
established NYSDEC certification standards. In combination with background heavy
metal levels, however, the standards may be equaled or exceeded, particularly for
cadmium, lead and mercury (MPI, 1978a). .
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The volume of return flow for the clamshell dredging operation will be 20
times less than that for the hydraulic dredge, because the water would be
recycled back to the pumpout barge.
A leachate will develop as a result of the drainage of the interstitial
water in the dredge spoil. MPI (1980b) has estimated that 344,000 cu m (91
million gal) of interstitial water will be entrained in the dredge spoil. The
substratum at the site will form an effective barrier to the downward migration
of this leachate. The substratum consists of a very poorly permeable clay with
~7 ~6 8
a permeability that ranges from 2.5 x 10 to 5.88 x 10 cm/s (9.8 x 10 to
2.3 x 10 in/s). At present the thickness of this material varies from 1.3 m
(4.5 ft) in the south to 17 m (57 ft) in the west. The site will be graded to
approximately 43 m (144 ft) above sea level. On the average, approximately 9 m
(30 ft) of clay will remain beneath the site once it is completed. EPA and
NYSDEC regulations regarding the siting of secure landfills requires a minimum
of 3 m (10 ft) of relatively impermeable material be above bedrock. This site
will satisfy these requirements. Migration of leachate from the base of the
-4 -4
site is estimated to occur at the rate of 2.4 x 10 m/d (8.0 x 10 ft/d). It
is expected to take 600 years for the leachate to travel a distance or 60 m (200
ft) to the property line (MPI, 1980d). The nearest well is approximately 500 m
(150 ft) west of the exterior dike of containment structure. Additionally, PCB
and heavy metal movement would be further retarded by adsorption onto the clay
particles, possibly reducing their movement 100 to 10,000 times below the water
flow rate (MPI, 1980d). Groundwater impacts from leachate generated at the
containment site are expected to be minimal.
The clay material at the site will not only serve as the base of the con-
tainment facility, but will also provide soil to form the exterior and interior
dikes. It is estimated that for water within the containment facility to seep to
the outside face of the dike it: would take in excess of 1,000 years (Richards,
April 22, 1980).
Noise levels in the area around the containment site will increase tempo-
rarily during construction of the facility and placement of the dredge spoil.
Construction noise will originate from heavy earth moving equipment, increased
traffic and other construction related activities. During placement the site
will operate 20 hours a day, generating noise from pumping stations, earth moving
equipment and increased traffic.
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Fisheries and Aquatic Biota
Discharge of return flow to the Hudson River will effect water quality
in the river. Return flow generated from the containment site during operation
would contain some PCBs and would be treated prior to discharge to the river.
The treatment process will consist of sedimentation, flocculation, and coa-
gulation and will only remove PCBs adsorbed to the solid material. Since the
treatment process will remove the solid material, effluent PCBs will be primarily
those dissolved in the water. Based on an average PCB concentration in the hot
spot material of 120 ug/g (ppm) and a maximum concentration of 1,516 ug/g (ppm),
the following effluent PCB concentrations are predicted (MPI, 1980d):
Average: 10 to 20 ug/1 (ppm)
Maximum: 100 ug/1 (ppm)
Minimum: 4 ug/1 (ppm)
Based on these projections, it is estimated that 70 kg (160 Ib) of PCBs
will be lost to the river with hydraulic dredging of the Thompson Island Pool hot
spots. With clamshell dredging and hydraulic cycle pumpout unloading, 9 kg (20
Ib) of PCBs will be lost for each year's dredging. If the pumpout water were
not recycled, an estimated 68 kg (150 Ib) would be lost during the first year
and 59 kg (130 Ib) during the second year (MPI, 1980d). Impacts to the
fisheries and aquatic biota will be less with clamshell dredging and hydraulic
pumpout unloading than with hydraulic dredging.
Site dewatering will produce an additional 344,000 cu m/d (91 mgd), which will
drain through a collection system to the river. At an estimated PCB concentra-
tion of 10 ug/1 (ppb), this drainage water would contain some 3.4 kg (7.6 Ib) of
PCBs (MPI, 1980d). Effects to aquatic biota and fisheries would be minimal.
Agriculture and Terrestrial Biota
The area around the containment site is used for growing of certain crops
and grazing of cows. Volatilization of PCBs from the dredge spoils will increase
levels in crops and grazing forage for fields near the site. Based on the PCB
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volatilization and dispersion models (Appendix J), the PCB levels in the various
crops (including corn with cob and ear only; corn with stem, ear, cob, tassle,
and leaf; alfalfa; red clover; and timothy) should be monitored at approximately
100-m (330-ft) intervals to a distance from the containment site at which all
foliar PCB levels are below the FDA maximum allowable level of 0.2 ug/g (ppm) for
forage. Based on work by Buckley (1980) it is expected that corn, with cob and
ear only, will be less contaminated with PCBs than corn with stem, ear, cob,
tassles, and leaves; corn with stem, ear, cob, tassles, and leaves will be less
contaminated than alfalfa; alfalfa will be less contaminated than red clover; and
red clover will be less contaminated than timothy. Therefore, vegetation should
be monitored before cattle are permitted to graze within 2,000 m (6,600 ft) of
the containment site.
Wildlife habitat at the site of the containment facility will be destroyed.
In addition, noise from construction activity will disrupt nearby wildlife
habitats and interfere with normal feeding, breeding, and nesting activities.
Maintenance Dredging and Navigation
Disposal of contaminated dredge materials will not have significant impacts
on maintenance dredging and navigation.
4B. Long-Term Primary Impacts
i
Public Health
Leachate will be collected by an underdraining system consisting of (1)
gravel filled collection trenches, wrapped with filter fabric; (2) perforated
drainage piping in the collection trenches; (3) collection and sampling well
along the containment area perimeter; (4) piping system connecting the drainage
system to a discharge point at the Hudson River and 5) flow meterizing and
monitoring system.
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The leachate collection system consists of gravel filled collection trenches
that have a potential for clogging if a large portion of fine grained sediment is
contained in the dredge spoil. If this happens, the interstitial water will be
unable to drain and the water will remain within the containment facility.
Although the capping material is very poorly permeable, MPI (1980c) estimates
that long term infiltration through the cover will be 3.1 cm (1.25 in) per year.
If this input is unable to drain out, it may develop a hydraulic head within the
closed containment facility that could lift the clay cover at a low point.
MPI (1980d) estimates that total annual leachate will be approximately
8,320 cu m/yr (2.2 million gal/yr). At 10 ug/1 (ppb), this leachate would
discharge 0.08 kg (0.2 Ibs) per year to the river. At present, leachate will be
drained to the river untreated, but options for leachate treatment are available.
However, estimates of leachate quantity and concentration indicate that effects
to the river will be minimal from the untreated leachate (MPI, 1980d).
Stormwater management controls are described in MPI (1980d). All site
drainage will be conveyed to the Hudson River during construction and after
closure. PCBs and sediment concentrations in the drainage may be elevated during
emplacement, but should decrease significantly after closure. Effects to water
quality in the Hudson are expected to be minimal. Additionally, the clay cover
will effectively prevent long-term migration of PCBs into the groundwater.
The shale bedrock underlying the containment site will bear the additional
weight of the filled and closed containment structure without rupturing or
collapsing. Presently, there is 9 to 22 m (30 to 75 ft) of saturated clay
overlying the shale. The addition of the dredge spoil to the clay overburden
will not effect the shale's ability to bear the weight of both the clay and
filled containment facility.
Once the contaiment area is stabilized and permanently capped, the vola-
tilization of PCBs will decrease markedly. An important factor in any long-term
4-64
-------
impact assessment would be which of the two options presently being considered
for the cap is chosen. One option included in the plan is the installation of a
capped continuous venting and control system. The other option is to install a
capped venting system immediately, but to wait and see if monitoring data show
that significant amounts of PCBs are being volatized before installing a control
system. Either of these options appear acceptable as long as the funding
for any future control system is set aside and available if necessary. In
addition, it appears that the second option may be most cost-effective as it is
quite possible that emissions from the covered containment site will be minimal.
4C. Secondary Impacts
The presence of a hazardous waste containment facility may lower market
values for adjacent property. In addition, state acquisition will remove real
property from the tax rolls and reduce the property tax revenues for the local
school district and local governments.
Use of the property as a containment facility will reduce the amount of land
available for development. This will not result in a significant shortage
of land for development because of the anticipated low rate of growth, current
lack of development pressure, and the already large supply of vacant land in the
region.
4D. Mitigating Measures
Unavoidable adverse impacts will originate largely from volatilization of
PCBs at the containment site during emplacement of dredge spoils. Mitigating
measures may be necessary to reduce the volatilization from sections of the
containment site nearest the local homes (section numbers 13, 14, 15, 16 and 17
indicated on Figure 4-1). After capping volatilization will decrease signi-
ficantly.
Mitigating measures that may be taken to minimize potential environmental
impacts from the containment site are:
4-65
-------
Protective clothing would be available for operators and other personnel
at the dredging and containment sites. This would include respirators
and protective gloves. PCB air concentrations at the containment site
will exceed the NIOSH 8-hour recommendation (1 ug/cu m), but they will be
well below the OSHA 8-hour standard (500 ug/cu m). Therefore, use of the
protective clothing would not be required.
A six-foot security fence should surround the active disposal area from
the initiation of site use (MPI, 1980d).
The containment site could be divided into smaller cells thereby reducing
total emissions at any given time during the disposal operations. High
surface tension monotnolecular films and adsorbents should be studied to
determine if their use would substantially reduce volatilization. Less
contaminated dredge spoils should be placed in those containment cells
nearest the occupied residences.
The clay cover should be put in place as soon as a given containment
site cell is filled and dewatered enough to support the weight of con-
struction equipment (MPI, 1980d).
Adequate topsoil, fertilizer, seed, and water will be applied to estab-
lish a thick vigorous cover. Over time the vegetation would be allowed
to revert to a mixture of pasture plants. The cover should be mowed a
minimum of once per year to prevent growth of deep-rooted plants (MPI,
1980d).
The cover surface would be inspected regularly for slope failure, cracks,
holes, and depressions. These would be filled and reseeded to maintain an
even surface. Lime would be applied periodically (MPI, 1980d).
Burrowing animals, such as woodchucks, which may inhabit the site, would
be controlled by trapping (MPI, 1980d).
4E. Contingency Plans
Despite the precautionary measures taken in the design, construction,
and operation of a containment facility, there still is some potential for
accidental failure of the containment area. Although this possibility is
considered remote, such an event would be likely to contaminate local groundwater
supplies. This would require New York State to obtain alternate water supply
sources or treat the contaminated supplies.
4F. Monitoring
Monitoring at the containment site will concentrate on PCB levels in ground-
water, leachate, stormwater runoff and air quality.
4-66
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ii : 8
CONTAINMENT
1 '"!'"!
: l7 I 16 i 14 i 12 i 9
20
22 ROUGHING AND 18
-/? )
TREATMENT
._ I
-
FIGURE 4 - I AREAS USED FOR CONTAINMENT SITE MODELING
Note: Arrow Shows Critical Wind Angle ( 58") Which was used
in Estimating Impacts at the Nearest Home (A)
75 150 225 METERS
-------
The groundwater monitoring network for the containment site consists of six
monitoring points adjacent to the active disposal portions of the site. Each
monitoring point will have three observation/monitoring wells:
A 3-m (10-ft) section; 3.8 cm (1.5 in) in diameter, schedule 80 PVC pipe
with 1 m (3 ft) of 10 slot screen;
A 6-m (20-ft) section; 3.8 cm (1.5 in) in diameter,schedule 80 PVC pipe
with 1 m (3 ft) of 10 slot screen;
A 9-m (30-ft) section; 10 cm (4 in) in diameter, schedule 40 PVC pipe
with 1.5 m (5 ft) of 10 slot screen.
These cased wells with friction type couplings will be installed by the
chopping and wash method. Each well will be backfilled with clean, well sorted
sand around and 0.6 m (2 ft) above the top of the screen. The remainder of the
hole will be filled with a bentonite grout and surrounded by a 1.5-m (5-ft)
protective sleeve with a locking cap.
When bedrock is encountered within the 9-m (30-ft) depth, the 10-cm (4-in)
in diameter well will be set 1.5 m (5 ft) into the bedrock (MPI, 1980a).
Leachate will be sampled periodically through the collection and sampling
wells connected to the drainage pipe. Storm water runoff will be collected and
sampled periodically (MPI, 1980a).
A system of gas sampling and venting wells will be installed in the con-
tainment area cover. These outlets will be valved to prevent the escape of
PCBs through volatilization. Gas pressure and compositon will be monitored
regularly and the valves will only be opened if necessary to prevent breaching of
the cap. If significant quantities of gas are generated, and if the gas does not
contain appreciable levels of PCBs, then the valves will be left open. If gas
does contain high levels of PCBs, appropriate provisions for collection and
disposal will be implemented (MPI, 1980a).
Volatilization during emplacement of the contaminated dredge spoil can
cause significant release of PCBs. The surrounding air quality and vegetation
will be continuously monitored for elevated PCS levels.
4-67
-------
Federal, State, Local, and
Other Sources from Which Comments
Have Been Requested
Abbreviations Used
Corresponding Metric and
English Units
References
List of Preparers
-------
FEDERAL, STATE, LOCAL AND OTHER SOURCES
FROM WHICH COMMENTS HAVE BEEN REQUESTED
Federal Agencies:
Army Corps of Engineers
Council on Environmental Quality
Coast Guard
Department of Agriculture
Department of Commerce
Department of Health and Human Services
Department of Housing and Urban Development
Environmental Protection Agency
Executive Office of the President
Fish and Wildlife Service
Geological Survey
Heritage Conservation and Recreation Service
Office of Management and Budget
United States Senate:
Honorable Alfonse D'Amato
Honorable Daniel P. Moynihan
United States House of Representatives:
Honorable Gerald Solomon
Office of the Governor:
Honorable Hugh Carey
New York State Senate:
Honorable Joseph Bruno
Honorable Hugh Farley
Honorable Ronald Stafford
New York State Assembly:
Honorable Joan Hague
Honorable Robert D1Andrea
Honorable Andrew Ryan, Jr.
State Agencies:
Department of Agriculture and Markets
Department of Commerce
Department of Environmental Conservation
Department of Health
Department of Transportation
Great Lakes Basin Commission
Power Authority
5-1
-------
County Agencies:
Dutchess County Environmental Management Council
Rockland County Department of Health
Washington County Board of Supervisors
Washington County Planning Department
Local Agencies:
Town of Greenwich Planning Board
Groups and Organizations:
Citizens Advisory Committee
Conservation Board, Town of Pound Ridge
Council of Agricultural Organizations, Inc.
Environmental Affairs Groups
Federation of Dutchess County Fish and Game Clubs, Inc.
Friends of Long Island
National Resources Defense Council
New Rochelle Environmental Impact Advisory Commission
Scenic Hudson Inc.
Settlement Advisory Committee
Sierra Club, Atlantic Chapter
Yonkers Environmental Impact Advisory Commission
5-2
-------
ABBREVIATIONS USED
a acre
BTI Boyce Thompson Institute
bu bushel
o
C Celcius
cfs cubic feet per second
cm centimeters
cu ft cubic foot
cu m cubic meter
cu yd cubic yard
CWA Clean Water Act
d day
DEIS Draft Environmental Impact Statement
EIS Environmental Impact Statement
EPA United States Environmental Protection Agency
o
F Farenheit
FDA United Staites Food and Drug Administration
ft foot
gal gallon
g gram
GE General Electric Corporation
gpd gallons per day
gpm gallons per minute
ha hectare
in inch
kg kilogram
km kilometer
1 liter
Ib pound
LMS Lawler, Ma.tusky and Skelly Engineers
Ipd liters/per day
1pm liters per minute
m meter
mgd million galIons/day
mg milligram
mi mile
6-1
-------
mm
MPI
MRJD
NEPA
NIOSH
NMPC
NOAA
NOI
NFS
NYSDEC
NIOSH
NOAA
NOI
NFS
NYSDEC
NYSDOH
NYSDOT
OSHA
PCB
PCFD
ppb
ppm
s
sq km
sq m
SEQRA
SHPO
USACOE
USDASCS
USDC
USFWS
USGS
USSCS
uv
millimeter
Malcom Pirnie, Inc.
Juser, Rutledge, Johnston and Desimore, Consulting Engineers
National Environmental Policy Act
National Institute for Occupational Safety and Health
Niagara Mohawk Power Company
National Oceanic and Atmospheric Administration
Notice of Intent
non-point source
New Yorl Policy Act
National Institute for Occupational Safety and Health
National Oceanic and Atmospheric Administration
Notice of Intent
non-point source
New York State Department of Environmental Conservation
New York State Department of Health
New York State Department of Transportation
Occupational Safety and Health Administration
Polychlorinated biphenyl
Polychlorinated dibenzofuran
parts per billion
parts per million
second
square kilometer
square mile
State Environmental Quality Review Act
State Historic Preservation Office
United States Army Corps .of Engineers
United States Department of Agriculture Soil Conservation Service
United States Department of Commerce
United States Fish and Wildlife Service
United States Geological Survey
United States Soil Conservation Service
ultraviolet
microgram
year
6-2
-------
Metric
, /o ,
celcius ( C)
centimeter (cm)
cubic meter (cu m)
gram (g)
hectare (ha)
kilogram (kg)
kilometer (km)
liter (1)
meter (m)
metric ton (t)
microgram per gram (ug/g)
microgram per liter (ug/1)
milligram per liter (mg/1)
millimeter (mm)
English
Farenheit ( F)
inch (in)
cubic yard (cu yd)
cubic foot (cu ft)
gallon (gal)
pound (lb)
acre (a)
pound (lb)
mile (mi)
gallon (gal)
yard (yd)
foot (ft)
ton (tn)
part per million (ppm)
part per billion (ppb)
part per million (ppm)
inch (in)
1
Note: 1. an approximate equivalent
7-1
-------
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Water Information Center.
United States Department of Commerce. 1976. Summary, New York State annual
climatological data. Volume 88, Number 13. National Oceanic and Atmos-
pheric Administration.
United States Environmental Protection Agency. 1976a. Quality criteria for
water. EPA-4409-76-023. United States Environmental Protection Agency,
Washington, D.C.
United States Environmental Protection Agency. 1976b. Review of PCB levels
in the environment. EPA-560/7-76-001. PS-253-735.
United States Environmental Protection Agency, 1976c. National Interim Primary
Drinking Water Regulations. U.S. Environmental Protection Agency. Office
of Water Supply, Washington, D.C. EPA-570/9-76-003.
United States Environmental Protection Agency, 1979. National Secondary Drinking
Water Regulations. U.S. Environmental Protection Agency Office of Drinking
Water, Washington, D.C. EPA-570/9-76-008.
United States Food and Drug Administration. 1979. An assessment of risk associ-
ated with the human consumption of some species of fish contaminated with
polychlorinated biphenyls (PCB's). HW-129. PCB risk assessment work
force, Washington D.C.
8-7
-------
United States Geological Survey. 1975. Water resources data for New York.
Water Resources Division, Albany, New York.
United States Geological Survey. 1980. Water resources data for New York.
Water Resources Division, Albany, New York.
Valentine, Ralph, S. 1981. LARC-light activated reduction of chemicals. Pollution
Engineering, February.
Vanoni, V.A. 1977. Sediment engineering. Prepared for Sediment Commission of the
Hydraulic Division of the American Society of Civil Engineers, New York, New
York.
Weber, J. B., and E. Mrozek, Jr. 1979. Polychlorinated biphenyls: phytotoxicity,
absorption and translocation by plants, and inactivation by activated
carbon. Bulletin of Environmental Contamination and Toxicology 23:412-417.
World Health Organization. 1974. LARC monographs on the evaluation of carcinogenic
risks of chemicals to man. Volume 7.
World Health Organization , 1976. Environmental health criteria 2: Polychlorinated
biphenyls and zerphenyls. Geneva.
8-8
-------
LIST OF PREPARERS
This EIS was prepared by WAPORA, Inc. under the technical direction of the
following EPA Region II Environmental Impact Branch personnel:
Robin Rohn
Thomas Maher
Richard Walka
Charles Manning
Steven Arella
Jeffrey Zeliksen
Project Officer
Environmental Engineer
Chief, New York/Virgin Island Section
Chief, Statewide Program Section
Chief, Environmental Impact Branch
Deputy Director, Water Division
The WAPORA staff members who prepared this document and their areas of respon-
sibility are listed below:
Howard Schwartz
Gregory Greene
James Mack
Kathleen Murray
Joel Soden
Principal Authors
Project Manager/Water Resources
Biology
Geology
Water Resources/Public Health
Air Quality
Alfred Angiola
Paul Eisen
Chris Salmi
David Bush
Louis Hajas
Michael Keller
James Marlowe
Roger Moose
Winston Lung
Mary Lou Motl
Catherine Skintik
San Kiang
Contributing Authors
Project Management/Air Quality
Air Quality
Air Quality
Air Quality
Engineering/ Water Quality
Public Health
Geology
Geology
Water Quality
Editing
Editing
Air Quality
9-1
-------
PAG E N OT
AVAILABLE
DIGITALLY
-------
PAGE NOT
AVAILABLE
DIGITALLY
-------
Plate 3
A'.
ROUGHING AND
STORAGE POND
O 75 150 225 METERS
ORIGINAL CONTAINMENT SITE
Source:
MALCOLM P1RN1E, INC.
-------
Plate 4
ROUGHING AND
STORAGE POND
TREATMENT
I PLANT
1/8 MILE
750 FEET
75 150 225 METERS
RE S COPED .CON T A I MM EN J SI ^TE
Source:
MALCOLM P1RNIE -INC.
-------
Appendices
-------
APPENDIX A
Human Exposure and Risk Assessment for Residents
in the Vicinity of Operations Associated with the
Dredging of the Upper Hudson River
The material in Appendix A was compiled by WAPORA, Inc. principally from the
following references:
United States Environmental Protection Agency. 1976b. Review of PCB
levels in the environment, EPA-560/7-76-001, PS-253-735.
World Health Organization. 1976. Environmental health criteria 2:
Polychlorinated biphenyls and zerphenyls, Geneva, Switzerland.
-------
Appendix A
HUMAN EXPOSURE AND RISK ASSESSMENT FOR RESIDENTS IN THE VICINITY OF
OPERATIONS ASSOCIATED WITH THE DREDGING OF THE UPPER HUDSON RIVER
1. HEALTH EFFECTS OF PCB EXPOSURE
A 1976 study by the World Health Organization (WHO) indicates that man
appears to be the species most sensitive to PCBs. The monkey is the only experi-
mental species in which effects qualitatively and quantitatively approaching
those in man have been observed; this has been attributed to metabolic dif-
ferences leading to a slower elimination than that observed in other species
tested.
Conclusions concerning the specific effects of PCBs on different species
are confused by uncertainty arising from the presence of toxic impurities.
Rice oil that caused an outbreak of severe disease in Japan was contaminated with
PCBs containing relatively high amounts of tetrachlorodibenzofuran, but the
sample used in the monkey experiments had low concentrations of these impurities,
so it is not clear whether PCBs alone were responsible for the incident in
Japan. Further uncertainty arises from reports from Finland of high PCB con-
centration in blood and body fat of occupationally exposed workers with no
indication of adverse effects, while at similar tissue concentrations Japanese
workers showed skin lesions (WHO, 1976).
Commercial PCBs are not sold on a composition specification, but on their
physical properties. Impurities known to be present in commercial PCBs are
chlorinated dibenzofurans and chlorinated naphthalenes. Chlorinated dibenzo-
furans have been found at 0.8-3.0 mg/kg (ppm) in samples of the Aroclor 1248-1260
series, but none in Aroclor 1016, and at levels of 8.4 mg/kg (ppm) in Clophen A60
and 13.6 mg/kg (ppm) in Phanoclor DP-6. Chlorinated dibenzofurans have also been
found at levels of 1 mg/kg (ppm) and 18 mg/kg (ppm) in different batches of
Kanechlor 400 (WHO, 1976).
A-l
-------
A species-specific toxic manifestation that can probably be attributed
to toxic impurities is the abdominal edema and hydropericardium seen in birds
affected by some commercial PCB mixtures (WHO, 1976)
Mink is another species with a high sensitivity to PCBs. Deaths have
been produced with diets containing PCB levels of 30 mg/kg (ppm); no information
is available on any species-specific metabolic pathway in the mink that would
account for this susceptibility (WHO, 1976).
The following is a summary of data concerning the relationship between
mammalian toxicity and dose. Approximate calculations of the daily dose in
mg/kg body weight derived from the dietary concentration are given in paren-
theses. When no food consumption figures were available from the experimental
studies, the following factors were used to transform mg/kg (ppm) in the diet to
mg/kg body weight: mouse (7), rat (20), guinea-pig (25), mink (10), rabbit
(33), monkey (25) (WHO, 1976).
la. Body Weight
Body weight was reduced in rats from 8 months of dietary intake of Aroclor
1254 and 100 mg/kg (corresponding to 5 mg/kg body weight); no effects were
observed at 20 mg/kg in the diet (corresponding to 1 mg/kg body weight) (WHO,
1976).
Dose-dependent retardation of weight gain was observed in mink after 4
months of dietary intake of Aroclor 1254 at 5 and 10 mg/kg (corresponding to
0.5 and 1.1 mg/kg body weight respectively) (WHO, 1976).
Ib. Effects on Liver
Liver Weight
Dose-dependent increase in liver weight was observed in rats receiving
Aroclors 1242, 1254 and 1260 at concentrations of more than 20 mg/kg in the
A-2
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diet (corresponding to >1.4 mg/kg body weight). Male rats were more sensitive
than female rats; no effects were observed with Aroclors 1254 and 1260 at concen-
trations lower than 20 mg/kg in the diet (corresponding to < 1.4 mg/kg body
weight). Effects were less marked with the lower chlorinated PCBs (WHO, 1976).
Liver Changes
Smooth endoplasmic reticulum proliferation with fat droplet inclusions
were observed in the liver tissue of rats after 8 months of dietary intake
of Aroclor 1254 at 20 mg/kg (corresponding to 1 mg/kg body weight). Liver
damage was observed with Aroclors 1242 and 1254 in rabbits receiving 14 weekly
oral doses of 150 mg/kg body weight; no effect was observed with Aroclor 1221
(WHO, 1976).
Liver Enzyme Activity
c
Increase in microsomal enzyme activity was observed in male rats after
8 months of dietary intake of Aroclor 1254 of 20 mg/kg (corresponding to 1
mg/kg body weight). No effect was observed at 2 mg/kg in the diet (corresponding
to 0.1 mg/kg body weight). Effects were less marked in female rats. Increased
activity was also observed with Aroclors 1242 and 1016 in male rats receiving 21
daily oral doses of 1 mg/kg body weight (WHO, 1976).
Liver Porphyria
Effects were observed in rats after several months of dietary intake of
Aroclor 1254 at, 100 mg/kg (corresponding to 5 mg/kg body weight); dose-dependent
effects were observed in female rats after 21 daily oral doses of Aroclor 1252
at 20 and 100 mg/kg (corresponding to 1 and 5 mg/kg body weight); no effects were
noted at less than 1 mg/kg body weight (WHO, 1976).
Liver Vitamin A
Reduction of hepatic vitamin A was observed in rats receiving Aroclor
1242 at the rate of 100 mg/kg in the diet (corresponding to 5 mg/kg body weight)
(WHO, 1976).
A-3
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Liver Tumors
Hepatocellular carcinomas were observed in mice after one year of dietary
intake of Kaneclor 500 at 500 mg/kg (corresponding to 75 mg/kg body weight); no
carcinomas were observed with Kaneclor 500 at 250 mg/kg in the diet (correspond-
ing to 36.5 mg/kg body weight), or with Kaneclor 300 and 400 at 500 mg/kg in the
diet (corresponding to 75 mg/kg body weight).
Hepatomas were observed in mice after 10 months of daily intake of Aroclor
1254 at 300 mg/kg in the diet (corresponding to 49.8 mg/kg body weight).
Hepatocellular carcinomas were observed in rats after 21 months of daily
intake of Aroclor 1260 at 100 mg/kg in the diet (corresponding to mg/kg body
weight) (WHO, 1976).
Ic. Reproduction
Effects on reproduction were observed in mice at a daily oral dose of 0.025
mg Clophen A60 and in the rat at a dietary level of Aroclor 1254 of 20 mg/kg
(corresponding to 1 mg/kg body weight) with the effects decreasing with higher
chlorinated PCBs; in the mink at a dietary level of Aroclor 1254 of 5 mg/kg
(corresponding to 0.5 mg/kg body weight); and in the monkey at a dietary level of
Aroclor 1248 of 2.5 mg/kg (corresponding to 0.1 mg/kg body weight).
Id. Immunosuppression
Immunosuppression effects were observed in the guinea-pig at a dietary
level of Clophen A60 or Aroclor 1260 of 50 mg//kg (corresponding to 2 mg/kg body
weight) (WHO, 1976).
le. Skin Effects
In man, symptoms of disease were observed at a dietary level of 4.2 mg/day
of PCBs (corresponding to 0.7 mg/kg body weight/day for a 60-kg person). A value
of 0.50 g was estimated as the quantity of PCBs consumed over approximately 120
A-4
-------
days above which toxic symptoms were evident. Similar effects were observed in
the monkey at a dietary level of Aroclor 1248 of 2.5 mg/kg (corresponding to 0.1
mg/kg body weight) after several months (WHO, 1976).
If. Nondetected Effect Levels
The assessment of non-detected effect levels for toxic effects is com-
plicated by the different activities of the component PCBs and by the presence
of impurities, in addition to the influence of inter-and intraspecies variation,
age, sex, and length of exposure. Moreover, many of the available experimental
studies do not include a non-detected effect level (WHO, 1976).
The most sensitive species appears to be man, and effects have been ob-
served at intake rates of 4.2 rag/day. This may have been influenced by the
intake of impurities more toxic than PCBs, but similar effects have been produced
in monkeys at the same order of dosage with a product containing little of
these impurities. At this dosage level, no effects may be expected on growth,
liver enlargement, and liver enzyme activity in .less sensitive species such as
the rat. Although non-detected effect levels are not available for effects on
immunosuppression and reproduction, and for certain biochemical effects on the
liver, it seems unlikely that these effects would be apparent at intake rates of
6 mg/day. Carcinogenic effects have been observed in rats and mice at dosages
two orders of magnitude greater than this, but there is not epidemiological
evidence to suggest that PCBs cause turmors in man. Rats fed a PCB diet at
the rate of 2 mg/kg (equivalent to about 0.1 mg/kg body weight) showed PCB levels
of 8 mg/100 ml in blood and 26.1 mg/kg in body fat. However, values much higher
than these have been observed in men occupationally exposed to PCBs without
evidence of any toxic effects (WHO, 1976).
2. HUMAN EXPOSURE TO PCBs IN THE VICINITY OF DREDGE AND DISPOSAL OPERATIONS
2a. Drinking Water
Residents along the upper Hudson River can be exposed to PCBs through
contaminated drinking water. Hudson River water is analyzed by the US Geo-
A-5
-------
logical Survey at five stations on the upper reaches; Glens Falls (above the
General Electric Plant), Rogers Island, Schuylerville, Stillwater, and Waterford
(Tofflemire, 1980). Although the Glens Falls PCB levels are usually below the
detection limit of 0.1 ug/1 (ppb), there are considerable data for the Schuyler-
ville and Stillwater sampling areas for the three years beginning in October
1976. Average PCB concentrations for these years were .687 ug/1 (ppb) in 1977,
.568 ug/1 (pb) in 1978, and .657 ug/1 (ppb) in 1979. Higher levels have been
reported for the 1974-1975 period at Rogers Island (1.5 ug/1) and levels as high
as 3 ug/1 (pb) were recorded in the Hudson prior to elimination of General
Electric discharges in 1976.
PCBs in Hudson River drinking waters can be reduced through treatment
(Tofflemire, NYDEC, 1980). If treatment is used by comramunities using the Hudson
as a source of drinking water, levels of PCBs in finished water could be reduced
from the present approximate level of .6 ug/1 to about .3 ug/1. The drinking
water standard for PCB is 1.0 ug/1. Since there was no significant difference in
the amount of PCB in the water for the three-year period between 1977 and 1979,
these levels probably represent background levels and residents using the Hudson
for drinking water, including wells and infiltration galleries near the river,
may assimilate approximately .3-1.0 ug/day at an average water consumption rate
of 2 I/day. Residents with alternative drinking water supplies will be exposed
to PCBs from atmospheric rain-out and fall-out into reservoirs and drainage
basins, but the extent of this exposure is currently unknown. There is no
evidence to indicate that these levels will exceed those in the Hudson River.
Ambient water PCB levels would increase due to return flow from the con-
tainment site and from the dredge plume (Malcolm Pirnie, 1980). In a "worst
case" scenario based upon clamshell dredging with hydraulic pumpout without
recycle, PCB levels would increase by .8 ug/1 immediately downstream from the
operation. The resulting ambient concentration of approximately 1.3 ug/1 would
yield a treated drinking water concentration of .65 ug/1 and an average daily
body burden of 1.3-2.6 ug/day for residents using the Hudson as a drinking water
supply. This increased body burden would also apply to the modified hot spot
dredging alternative although the period of chronic exposure would be reduced.
A-6
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2b. Food
Comprehensive human food monitoring data on levels of PCBs are not avail-
able for the Hudson River area. However, the Food and Drug Administration (FDA)
conducts a comprehensive food surveillance program yearly to determine pesticide
residues, PCBs, heavy metals, and other contaminants in the diets of consumers in
the United States. These studies, conducted since 1969, indicate that PCBs are
most commonly found in fish, both freshwater and marine, although they have also
been detected in other foodstuffs (USEPA, 1976b). An FDA total diet study based
on FY 70 and FY 71 data showed composite food samples containing PCB residues of
up to .36 ppm. The positive readings were found in meat, fish, poultry, dairy,
and grain and cereal composites.
FDA's FY 73 study included thirty market basket samples from representative
areas of the United States consisting of the total 14-day diet of a 15-20 year
old male (USEPA, 1976b). About 117 individual food items were analyzed. Most of
the PCB levels were trace amounts. The most frequent occurrences were in the
meat-fish-poultry and grain-cereal products groups. The range of concentrations
encountered was trace to 0.73 ppm.
In the FY 74 study, there were positive findings of PCBs in two food groups:
sugar and adjuncts, and meat-fish-poultry (USEPA, 1976b). Only 3% of the samples
in the first group were positive, while 45% of the second group had detectable
levels of PCBs, with fish as the usual source of contamination. Data for 1975
indicated PCB contamination in 40% of the meat-fish-poultry samples and no
positive findings in any other food groups.
Based upon these data, FDA has estimated the average daily intake from
all food group composites and the average daily intake from the meat-fish-
poultry class (Table 1). The decrease in total diet exposure is due to de-
creasing levels of PCBs in food packaging materials. The ingestion of PCBs
through food should level out (based upon national background levels) and
continue at the 1975 level as long as fish remain almost the sole source of
dietary PCBs.
A-7
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Table 1. Estimates of Total Daily PCB Ingestion (FDA, 1979).
Average Daily Ingestion of PCBs (ug/day)
Fiscal Year Total Diet Meat-Fish-Poultry Class
1971 15.0 9.5
1972 12.6 9.1
1973 13.1 8.7
1974 8.8 8.8
1975 (1st half) 8.7 8.7
The FDA studies are based upon national data and do not reflect actual
conditions along the upper Hudson River although food levels in the dredge area
could not be expected to be below national averages. Monitoring of foliage near
dump sites indicated PCB levels of from .1 to 58 ppm (USEPA, 1976b). Background
levels were recorded beyond 700 meters from the dump sites. Since cows fed diets
containing 10 ppm and 100 ppm PCBs produced milk containing 6.27 ppm and 75.4 ppm
PCBs (WHO, 1976), dairy herds grazing on foliage at 58 ppm would produce milk
containing between 36 ug/1 and 43 ug/1 PCBs, far above the FDA limit of 1.5 ug/1.
The WHO study (1976) reports that these PCBs survive processing into dairy
products, and most was located in milk fat. Foliage levels at the Moreau dredge
spoil site did not exceed 1.4 ppm.
Given the potential contamination of grazing land and residences near the
containment site, volatilization and aerosol contamination by PCBs should be
minimized prior to capping with a clay seal.
Since 1975 FDA data indicate that the meat-fish-poultry food category is
primarily responsible for dietary intake of PBCs, suspension of the ban on
fishing in the upper Hudson River must be considered for its effects on local
population dietary exposure to PCBs. The FDA data on fish concentrations ranged
from trace to .05 ppm (USEPA, 1976b) while data on PCB levels in upper Hudson
River fish indicate levels ranging from 20 ppm to greater than 500 ppm (Thomann
A-8
-------
and St. John, 1979). Recent trend analyses on levels of PCBs in upper Hudson
River fish indicate that a 5 ppm level may be reached by the mid-1980s without
dredging and possibly sooner if contaminated sediments are removed (Armstrong and
Sloan, 1980). Temporary elevations in tissue PCB levels can be expected from
increases in PCB levels in the Hudson that result from dredging activities.
For populations along the Hudson that do not consume fish taken directly
from the river, exposure to PCBs through the ingestion of food would be at
least 9 ug/day, the national background level (USEPA, 1976b). Consumption
of Hudson River fish with PCB levels at the FDA action level of 5 ppm would
increase this amount one-hundred fold to approximately 900 ug/day (0.9 ing/day).
These exposure levels would apply equally to the no action, hot spot dredging,
and re-scoped hot spot dredging alternatives. Since effects on humans have been
observed at 4.2 mg/day, a diet that includes up to 1 mg PCBs/day could not be
considered' safe 'for sensitive individuals in the local population, 'particularly
since inhalation and drinking water exposures would increase the daily body
burdens.
2c. Inhalation
5 Exposure to vapor phase or aerosol PCBs will be greatest for workers
involved in the dredging and containment operations and nearby residents, and
of less significance for the general population in the vicinity of the upper
Hudson River. At several PCB dump sites in the Fort Edward and Glens Falls
area, concentrations exceeded the NIOSH 8 hour recommendation of 1 ug/m , with
3
levels at the Caputo site of up to 130 ug/m during the summer (MPI 1980d).
Sediment concentrations of PCBs at the Caputo site were 10,000-50,000 ppm.
Workers at the Monitoring data taken near Buoy 212 during dredging in the Fall
of 1979 indicated atmosphere levels of .5 ug/m .' The populace In "Fort Edward
3
and Hudson Falls is exposed to a general background concentration of .05 ug/m .
In addition, average indoor kitchen air has been reported to be 0.32 ug/m
(USEPA, 1976b).
A-9
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3
At an average working inhalation rate of 0.05 m /min, workers at the
3
dredge sites could be exposed to up to 12 ug/8-hour shift (.05 m /min) (.5
3
ug/m ) (60 min/hr) (8 hr/shift) = 12 ug/shift) and workers at the containment
3 3
sites could be exposed to 3,12 ug/8 hour shift ((.05 m /min) (13 ug/m ) (60
min/hr) (8 hr/shift) = 3,120 ug/shiftj) The potentially excessive exposures for
containment site workers can be mitigated by personal protective equipment or by
engineering controls. Residents in the vicinify of the upper Hudson will be
exposed to from 0.7 ug/day to 4.6 ug/day, calculated upon inhalation of atmos-
3 3
pheric background levels of .05 ug/m and indoor levels of .32 ug/m .
2d. Summary
In man, symptoms of disease were observed at dietary levels of PCBs of
4.2 mg/day (WHO, 1976). Similar effects were seen in rhesus monkeys administered
the same dose. Effects on liver function, reproduction, immunosuppression, skin
health, and incidence of hepatocarcinomas have a}so been noted in various spe-
cies. There are insufficient data to calculate dose-^response relationships for
humans, and a non-effect level cannot be determined.
Common contaminants associated with PCBs include chlorinated dibenzofurons
and benzodioxins (WHO, 1976). A single oral dose of chlofinated dibenzofurans
of .5-1.0 mg/kg body weight caused severe and often lethal liver necrosis in
rabbits. This corresponds to a single human dose of 33-65 mg for a 65 kg human.
.Chlorinated dibenzofqrons have been Calculated to be approximately one order of
magnitude less toxic the chlorinated benzodioxins.
If the PCBs in the ljudsbn are _npt removedf ?pt**l daily exposure to PCBs
will be approximately .OlOrO.15 mg (9 u§ from food, .3 ug from drinking water,
and .7-4.6 ug inhaled). This level will not change significantly during and affer
dredging provided the dredge spoil containment area and dredge spoil barges are
covered to prevent atmospheric losses of PCBs. Without prepai»tions, workers
at the containment area could be exposed to up to 0.3 mg/day, and cows feeding on
forage near the containment site could be contaminated tp levels in excess of FQA
A-10
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limits. If the ban on fishing in the upper Hudson River is rescinded and these
fish become a part of this local diet, another .9 mg/day would be added to the
diet.
In addition to the recommended engineering controls, monitoring of the
Hudson River and foliage and milk in the vicinity of the dredge and containment
areas should be implemented. In addition to analyses for total PCBs, the levels
of PCB contaminants such as chlorinated benzodioxins and dibenzofurans should be
monitored. Since the sediments are also known.to contain high levels of cadmium,
chromium, lead, and zinc (MPI, 1980d), analyses for these toxic metals should be
included. The analyses should not be limited to raw river water but should be
extended to include finished drinking water from treatment plants with intakes on
the Hudson as well as groundwater and infiltration gallery sources of drinking
water downstream of dredging and containment operations.
It is unlikely that human exposure to PCBs will increase if no action is
taken to remove contaminated Hudson River sediments, provided the sediments
are not disturbed by natural or anthropogenic scour. If the sediments are
resuspended, increases in atmospheric, fish, and drinking water levels can be
expected although there are insufficient data to quantify the increases and
resultant human exposure. Dredging and containment operations would not in-
crease human exposure significantly beyond background levels if the additional
engineering controls are implemented. Reopening of the fishery would increase
human exposure to consumers of the fish by 100 fold.
A-ll
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An Assessment of Risk Associated with
.the Human Consumption of So;ne Species of
Fish Contaminated with Polychlorinated
. Biphenyls (PCB's)
June, 1979
Requested by: Donald :Kennedy
Cornrm'ssioner, FDA
Prepared by: PCS Risk Assessment Work Force
* p u ty As s o c ~i a tc Con.^ i s 3 i o n e r
for Hsaltii Affairs (Science)
A-12
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An Assessment of Risk Associated with
the Human Consumption of Some Species of
Fish Contaminated with Polychlorinated
Biphenyls (PCB's)
The risk assessment reported in this paper was conducted in connection
with a pending Food and Drug Administration (FDA) rulemaking preceding
involving proposed reductions in the tolerance levels for PCB's in va-
rious categories of food, including fish and shellfish (Docket No.
77N-003Q). FDA has proposed, inter alia, to reduce the tolerance for
fish and shellfish from 5 ppm to 2 ppm (see the Federal Register of
April I, 1977, 42 FR 17487). -Most of the toxicity data on PCB's has
alrsa:;v been presented in this proposal. However, the available data
v;£re not utilized for performing a human risk assessment under the
conditions of various, possible tolerances; i.e., no tolerance, 5 ppm,-
2 pprr., or 1 pp;n PCB tolerance for fish and shellfish. Furthermore,
certain data relevant to assessment of the levels of PCB exposure and
the toxicity of PCB.during reproduction and lactation have been
reported sinca the proposal was published; these data are also
reviev.'sd. The purpose of this risk assessment is to assist the agency
in its estimation of the degree to which risk to consumers would be
reduced by the proposed reduction of the tolerance for PCB's in fish.
«
The term PCB's refers to a complex mixture of chlorobiphenyls.
Commercial PCB products, manufactured in the United States exclusively
~A-13
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by the Monsanto Company, are identified by the trade name "Aroclor,"
r .
and the particular PCS as, for example,.Aroclor 1254 or Aroclor 1250.
«
The first two digits refer to the fact that the biphenyl is made up of
12 carbon atoms, and the second two digits refer to the approximate
percentage by weight of the chlorine content in the mixture. Thus,
Aroclor 1254- contains 12 carbon atpms and approximately 54 percent
chlorine, while Arcclor 1260 contains 12 carbon atoms and
approximately 60 percent chlorine.
PCB's v;sre reportedly first synthesized in 1831, but they were not
cohere-sal ly available until 1930 (DHEW, 1975). By late 1971, tha
.widespread, uncontrolled use of PCB's in a variety of industrial
applications had resulted in their becoming a persistent and
jt . , ,- '
tViquitous environmental contaminant,
»
Ope consequence of this environmental contamination with PCB's has
bean the contamination cf certain foods, including fish and shellfish.
Though human exposure to PCB's occurs to a limited extent through the
air 'and'-water, the most significant exposure now appears to be from
dietary sources, especially from consumption of freshwater fish from
contaminated waters. Human breast milk is another source of these
substances. '
/
The risk assessment reported here uses toxicity data from animal
studies, human exposure data, and a mathematical extrapolation model
to arrive et estimates of risks posed by exposure to PCB's assuming
A-14 .
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the imposition and enforcement of three possible tolerance levels5
ppm, 2 ppm, and 1 p?m. This paper will first discuss some of the ...
*
toxicity data available on PCB's. Following that will be a discussion
of the calculations made regarding human exposure to PCB's through
fish consumption and, finally, the results of the risk assessment.
Toxicity of PCB's .
A. Human Data :
. Considerable scientific interest has centered on the Yusho
incident in Japan in 1863, involving human intoxication v/ith Kanschlor
403 (a brand of PCS's manufactured in Japan). The incident occurred
as a result of tha consumption by Japanese families of rice oil
\
("Yusho" oil) that had been contaminated accidentally with Kanechlor
r.
400. . . .''".
The typical clinical findings of "Yusho" disease included
c/nloracns and increased pigrnantaiion of. the skin, increased eye. dis-
charge, transient visual disturbances, feeling of weakness, numbness
in liris., headaches, and disturbances in liver function. Most of the
babies born to mothers with the Yusho syndrome were small and had skin
discoloration that slowly regressed with age. Adult Yusho patients
had protracted clinical disease with a slow regression of symptoms and
signs, suggesting a slow metabol ism and excretion of PCB's in humans,
probably resulting from a long biological half-life. A total of 1291
A-15
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Yusho disease cases have been reported up to Kay, 1975 (NIOSH, 1977).
Originally, the effects seen in the Yusho incident were
attributed exclusively to PCB's, which had been thought to be the sole
contaminant of the rice and had been identified in the blood and .
tissues of Yusho patients. In the review by Kuratsune _e_t _al_. (1975),
a new factor was introduced: the canned rice oil was shown to be
contaminated also with polychlorinated di'benzofurans (PCDF's) to the
extent of 5 ppm. In addition, Kuratsune presented data of Nagayana
£t £l. (1975) showing PCDF's to be present in the liver and adipose
tissue of Yusho patients, while none was found in that of a control.
group. The ratio of PCB's to PCDF's in the Yusho oil (containing
"used" Kaneehlor 400) was 200:1, whereas the ratio of PCB's to PCDF's
r.
in "unused" (unheatad) Kanechlor 400 is 50,000:1. Thus, with respect
to PCB's, the ratio of PCDF's in Yusho oil to.PCDF's unused Kanechlor
430 is 250:1. Also, the toxicity of PCDF's ranges from 200 tc 500
times that of PCS's (Cordla et al., 1978). Thus, for. equal amounts of'
rice-oil and pura Kanschlor 4CO, the toxicity of the rice oil would
rang= from 2 to 3.5 times that expected from its PCS content alone.
Uncertainty about the confounding of effects between PCB's and
PCDF's makes it difficult to determine from the Yusho data exactly
what effect(s) exposure to only PCB's could have on humans. Detailed
A-16
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records of the 1291 Yusho patients have been maintained in an effort
to detect possible long-term effects. At least.9.out of the 29 deaths
that occurred as of May," 1975 have been attributed "to malignant neo-
plasms (NIOSH, 1977), but a causal relationship between PCB's and
cancer cannot be inferred because of the confounding introduced by the
presence of PCDF in the oil. The Yusho study, nevertheless, can lead
to two important observations: first, PCB's can be transferred from
mother to fetus and from mother to child through breast feeding; and
second, highly chlorinated PCS compounds are excreted more slowly from
the body than the less chlorinated ones (NIOSH, 1977).
Finally, in a study of chemical workers (Bahn jet _al_., 19.76,
1977), two malignant melanomas v/ere diagnosed in 31 workers exposed
heavily to Arochlor 1254 (an-J also exposed to other chemicals that
could possibly cause cancer). It was estimated that .04 malignant
-elanornas would have been expected from this croup of individuals.
A~,ang 41 other workers also exposed to Aroclor 1254, but less
heavily, one additional melanoma was diagnosed.
Data free; Lifetime Anirnal Feeding Experiments
A number of studies have evaluated the neopl'astic potential cf
PCS ingestion (Ito, 1373, Under et_ _al_., 1974, Kimbrough et._cK» 1972,
1974, 1975, Calandra, 1975, NCI, 1978). Each of these studies
A-17
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provides some evidence'that neoplastic lesions can be induced by PCS
.exposure* However, only three of these were of-sufficient duration to .
be of value in assessing the lifetime carcinogenic p'sk of PCB's.
These three studies are the following:
1) Effect of Aroclor 1260 on Female Sherman Rats
JRimbro'jgh et a 1,, V°75|'
In this study, .200 Sherman strain female rats were fed a diet
containing ICO'ppm of Aroclor 1250 for approximately 21 months,
end treatment was discontinued for 5 weeks before the animals.
v,'sr? sacrificed at 23 months. A group of 2QO untreated female
rats served as controls. All animals were observed daily;
moribund animals were sacrificed and subjected to gross and
microscopic pathological examination, as were the animals sacri--.
ficed at the end of the experimental paripd. A total of 184
dosed rats and 173 controls survived to the end of the experi-
«
ment. The authors concluded that Aroclor 1260, whan fed in the
diet, had a hepatocarcinogenic effect in these rats. No. signifi-.
cant differences could be observed between experimental and
control animals with regard to the incidence of tumors in other
organs.
Although this study provides strong evidence of the
carcinogenic potential of PCB's, certain prtocol design elements
preclude this study from being considered adequate'by today's
A-18
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standards. These deficiencies include the use of only female
rats; lack of in utero exposure in the light of evidence that
suggests j[n utero effects; sacrificing the "animals at a rela-
tively early time of 23 months, considering the expected life
span of 25-30 months; and continuing dosing only up to 21 months,
However, these shortcomings would, if anything, tend to mask or
understate the true carcinogenic potential of PCB's.
2) National Cancer Institute (197S) Bioassay of the
Carcinogenic Effect of Aroclor 1254 In Flshsr 344
Rats
In a bioassay of Aroclor 1254 (National Cancer Institute,
1978}, groups of male end female Fisher 344 rats (24 of each ssx
per group) were administered the test compound in the diet at 25,
A .
C. ' '
50, and 100 pp-n for a period of 104-105 weeks. Matched controls
consisted of groups of 24 untreated rats of each sex. All eni-
ricls were observed daily for signs of toxicity and palpated for
»
tissue masses at each weighing. Moribund animals were observed
daily for signs of toxicity and palpated for tissue masses at
each weighing. Moribund animals were sacrificed and subjected to
gross and microscopic pathological examination, as were the cm"-
*
mals sacrificed at the end of the experimental period* It was
concluded that "under the conditions of this bioassay, Aroclor
1254 was not carcinogenic in Fisher 344 rats; however, a high
incidence of hepatocellular proliferative lesions in both male
A-19
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8
and female rats was related to the administration of the
chemical. In addition, the carcinomas of the gastrointestinal
tract may be associated with the administration of Arcclor 1254.
in both males and females."
Although Arcclor 1254 was not shown to be carcinogenic by the
NCI bioassay, it must be kept in mind that this was a relatively
small experiment utilizing only 24 animals per dose .group per
sex. Tc provide statistical sensitivity for detection of cancer,
the usual number of animals pgr group for an NCI bioassay is 50,
A lively rear.on this bioassay is smaller than most may be because
this study v/2s pa~t of a larger study designed to assess the
combined effects of a group of chemicals. Overlooking for the
i /*
moment the r'^ct that the protocols were different than the so use-:.
for a standard cancer bioassay and different Aroclors were
tested, the re5:jV-s of the NCI bioassay and the Kimbrcugh study
are not en^ir^ly inconsistent. Both studies indicate that the
liver is the target organ for toxicity, and a high incidence of
prpliferativa lesions occurs in both studies. Furthermore, if
the same percentage of animals exhibited carcinomas in th-2 NCI
study as in the Kinbrough (1975) study, the high dose (100 ppm)
group in the NCI study would exhibit only 3 carcinomas out of the
24 animals/sex used in this study, (This compares closely to
the 2 carcinomas the NCI study found in this dosage group.)
A-20
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Nevertheless, due to the small number of animals in the NCI
study, it is not presently possible from the NCI bioassay data to
support either a carcinogenic or noncarcinogenic response with
RGB's in Fisher 344 rats.
3} Industrial Bio-Test Experiment (1971) with Charles River
Rats
This experiment was performed by Industrial Bio-Test
Laboratories (1971), and a summary of results was presented at
the National Conference on Polychlorinated Biphenyls (Calandra,
1975). On? thousand Charles River strain albino rats v/era placed
into 10 treatment crcups. One hundred rats (50 male end 50
female) served as controls and 100 rats {50 male and 50 female)
were assigned to each of nine treatment groups which were fed
diets containing 1, 10, and 100 ppm of Aroclors 1242, 1254, and
1260, respectively. Dosage started when the animals ware about
4-5 weeks old and continued for 24- months. The liver slides from
this study have been examined twice by paths!ogists, cr.ce in the
original report {Industrial Bio-Test Laboratories, 1971) and in a
later report {Monsanto, 1975). The diagnoses in these two exam-
inations ware disparate, e.g., for animals dosed at 100 ppm, the
first examination diagnosed one hepatoma and two animals with
nodular hyper-plasia, wheraas. the later examination diagnosed
A-21
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10
eleven animals with hepatomas and tvyenty-eight animals with
v
nodular hyperplasia. '
For unexplained reasons, there was also unusually high
mortality among the rats in the experiment, and the numbers of
rats were further reduced by interim sacrifices during the coursa
of the experiment. . For example, only 6-21 animals out of the
initial 100 in each treatment/sex subgroup fed 100 pptn survived
to the terminal sacrifice. The FDA has found many such abnor-
malities with wor!< conducted by Industrial Biotest Laboratories
and has disqualified this study as a valid carcinogenic study and
considers the findings unreliable. Nevertheless, re-diagncsis of
r,
the liver pathology indicated a significant tumorigenic effect.,
The incidence of nodular hyperplasia was significantly elevated
in the group fed 10 pp.^i Aroclor 1260 over the incidence in the
control group. There are 2 total of 9 hepatomas in the groups- '
fed 100 ppm of one of the three Aroclors, but none in the groups
fed lesser concentration of PCB's. Because this study is consid-
ered unreliable by the agency, it will not be used for estimating
risk, but is presented es supportive data only.
Examination of the literature available on PCB tbxicity
indicates various types of toxicity other than carcinogenicity.
A-22
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11
These toxicities include teratogenesis, reproduction effects, behavior
effects, skin disturbances, edema, etc. This report is not ignoring
these effects but is addressing only estimated human lifetime risks to
cancer and not each of the other reported toxicities. Certainly, data
fcr all types of toxicitywill be considered in assessing the overall
safety of PCB's in the diet.
V
4) Additional Toxiclty Data
A recent presentation of Barsotti j2t._al_. (1979) indicates that
fenale Rhesus monkeys exposed to PCB's exhibit reproduction end neon-
atal toxicity in their offspring even after PCB exposure has been
discontinued for over a_.year. Details of this, study were provided to
us by Dr. J. R. Allen (1979) in the form of a draft scientific paper.
o ' '
Aroclor 1248 (PCB) was fed to eight female Rhesus monkeys
at levels of 2.5 and 5.0 pp:n in the diet. After six months, they were
mated to control males. Six of eight females fed at 5.0 pp;n conceived
but only one was able to carry to term. Most of the abortions
occurred during the first 45 days of pregnancy. All of the animals
fed at 2.5 pprn conceived and five gave birth. During nursing, milk
PCB l&vsls were 3.85-9.9 ppm (on a fat basis). Within two months
follov/ing birth, the infants had facial acne and edema, swelling of
the eyelids, loss of facial hair including eyelashes, and hyper-
A-23
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12
pigmentation of the sk.in. Three of the six infants died during their
first year of life due to PCS intoxication (Allen, and Barsotti,
1976).
To evaluate the prolonged effects of PCB's on adult female
primates, the PCB-containing diets were discontinued for approximately
one year and the females were again mated to control males. No con-
trol female to control male matings were performed. All the females
conceived. Four of the seven 5 ppm animals gave live births while
seven of the eight 2.5 ppm females gave live births and one had an
abortion! At birth, the infants from the 5.0 ppm group -ware -generally
smaller than the historical control infants.. The 2.5 ppm infants
shov/ed considerable weight variation. . .
-. r^ .
a
During th-2 four months of nursing, the infants of both groups
developad 'r-yperpig-.sntation about their hairline. Analysis of the
milk that the infants were consuming at the time they were weaned
revealed FCB levels of from 0.9 to 1.25 ppm (on a. fat basis) corr.pared
to 3.35-^9.3 ppm previous to discontinuing PCS treatment. Two infants
from each group died following weaning. Prior to dea£h> these.infants
became anoretic, lost weight, and developed swollen eyalids, loss of
t
eyelashes, scaly skin, acne and alopecia (all signs of PCB
poisoning). .
A-24
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13
It can be cb.iv-Vuded that one and a half years^-a-h-er exposure to
PCB's and with the milk PCB levels considerably reduced from previous
levels, there was enough PCB in.the .milk to increase the body burden
in the infant and cause PCB poisoning.. It should be noted that during
the time the females were off the PCB diet there had been a dramatic
decrease in the PCB content of the subcutaneous fat of the adult
animals. Nevertheless, when these animals were lactating, the PCB
content .of the milk fat had changed less drair.ctically than expected
i
from adipose tissue levels. These data suggest that during lactation,
PCB's are concentrated in the'nrilk fat and accumulate in infants to
levels higher than in their mothers.
A study by Kuwabara _e_t__al_. (1973) presents convincing hurnsn
evidence that brest-fed, children of mothers exposed, to PCS's have
much higher blood PCB levels than controls. Furthermore, the blood -
o "
iGvals in children who breast feed for greater than thres months were
higher thsn their wethers* A correlation between duration of breast
feeding and blood levels was shown. These data are presented in more
detail under a subsequent section of this .document on Human Milk
Exposure to PCo's. ' . ' .
In conclusion, these newly reported data present the agency with
a difficult task in protecting the unborn and newborn young. At the
present time, we are unable to assess the long-term risk from
increased exposure to PCB's during a relatively short part, e.g. (six
months to one year) part of the total lifespan of an individual.
Ordinarily, adequate protection from such effects can be attained for
children and adults if a level of toxicant producing no observable
A-25
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14
adverse effects, is determined; however, the data available do not
*
i * .
permit establishment of such a "no-effect" level in monkeys.
»
Furthermore, because the infant is undergoing tremendous growth and
differentiation during this period, it is possibly even more
susceptible to PC3 intoxication than is the adult.
' t
Estimated Human Exposure Levels
A- FDA Total Diet Program
Using the FDA Total Diet Program data (Johnson and Manske, 1977) '
an estimate of PCS exposure from all dietary sources for 1974-1975 was
compiled (Jelinsk and Corneluissen, 1975). These values, which 'sre
listed in Tables 1 ar.d 2, must be viewed as only crude estimates since
in prder to obtain them numerical values had to be assigned to trace
observations. Those levels that were reported as trace ware con-
sidered to be at one-half the quantitative lower level of detection,
i.e.., oO.?5 ppm. Examination of Tables 1 and 2 indicates that the
predominant food class in v:'nich PCB's were detected from 1974 to 1977
was meat,-fish, and poultry. The majority of these positive findings '
are dua to PCB's in fish samples. It appears from Tables 1 and 2 that
the averaci* doily PCS intakes from the meat, poultry, and fish cate-
gory have remained fairly stable (7.9 - 9.1 [g/day) since 1972, while
levels in oth?r foodstuffs.have decreased to nondetectable levels.
A-26
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15
B. PCB Levels In Fish
As pointed out -in the previous section, the most significant
exposure to PCB's in food is" through fish, Tables 1, 2. The distribu-
y "
ticn of total commercial fish consumption can be calculated from the
Seafood Consumption Study (National Marine Fisheries Service, 1975),
but the distribution of consumption of other freshwater sportsfish
species is not available. Moreover, the concentration of PCB's in
t
fish is highly variable, both among species and within a single
.-1" '
species. Fish caught further offshore tend to have smaller amounts of
PCS's than estuarine fish, and freshwater fish caught in areas of high
?C3 pollution tend to have the highest concentrations of PCB's,
Furthermore, sports fishermen would.consume varying amounts of fish.
The activities of sports fishermen are not and cannot be regulated by
the FDA, -
a
1} Estimate of Human Exposure to PCS's Through Commercial Fish
Consumption . " ~ ':~
In order to determine human -exposure to PCBJs through
corr.rriGrcial fish, it is necesary to know the levels of PCB rest
dues in the edible portions of fish.consumed by the population.
Information has been compiled by the National Marine Fisheries
Service-NOAA (1976) en the most important types of fish in the
U.S. diet and on the mean daily amount of each type consumed by
those who actually consumed that type. This study included
25,947 eaters selected as a sample representing all fish eaters
in the United States.
A-27
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16
Information from the survey shows that some twenty species
comprise 95% of all the fish products eaten. Although 932 of the
U.S. population (197 million) eat fish, the average annual per .
(,.^j
capita consumption of fish is snail: 15.0 Ib/year. A major
portion of total consumption consists of "unclassified" fish,
1 \
ranking just below tuna in importance. This "unclassified" fish
s ' .
consists of a variety of species, each of which considered
separately would make up pnly a minor portion of the diet.
Freshwater species, led by trout, bass, and catfish, comprise
about 9% of our total fish diet. -..
Table 3 lists the 12 fish categories of interest, i.e.,
&
the 11 species of fish found in the. FDA 1978-1979 survey to have
the highest PCB residue levels and all other spscie? grouped '
under "all other," and gives the rriean PCB levels in these species
assuming the absence of an FDA tolerance 'end' assuming 'the
imposition of tolerances of 5 ppm, 2 ppm, end 1 ppn. A rough '
approximation of the. effect of a given tolerance on mean PCB
levels for each species was arrived at by eliminating samples
with PCB levels above the assumed tolerance' and recalculating the
mean.
A-28
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17
Table 4 lists estimated human exposure levels corresponding
to no tolerance, 'and tolerances of 5 ppm, 2 ppm, and 1 ppm for
those 3939 persons who ate the species of interest. Because
analytical, methods for regulatory purposes are hot presently
available for PCS levels below 1 ppm in fish, (i.e., due to
analytical limitations, it would not now be possible to impose a
tolernce at levels less than 1 ppm) no exposure estimates were
t
made for levels below 1 ppm. The estimated daily exposure levels
s
were arrived at by multiplying the consumption par day of each of
tha species of interest (at both the 50th and 90th percentile
consumption levels) by the mean PCB level for each type of fish
assuming no tolerance and tolerance levels of 5 ppm, 2 ppm, and 1
ppm. The figures in Table 4 reflect the total estimated daily-
exposure frcrn the 12 species of interest. The risks estimated on
-------
18
been sufficiently'representative or extensive to provide a reli-
able estimate of the distribution of PCS levels in each species.
It should be noted that the mean PCB levels based on an assump-
tion of no tolerance may not reflect all PCB levels occurring in
fish because the 1978-1979 survey was carried out when a toler-
ance of 5 pp(n was in effect, Thus, tha effect of going from no
tolerance to a tolerance of 5 ppm may be greater than shown
hare.
Estimated SportsL Fisherman Exposure to PCB's from Sports
Fish Consumption
The National Fish and Wildlife "onitoring Program has
followed PCB levels .in freshwater fish for many years. Walker,
!".
1976. summarized these findings ac follows:
"Geographically, the higher concentrations appear to
be associated with certain river systems having industrial
activity.... PCB residues expressed as Aroclor 1254 were
found in five major river systems in the Atlantic coastal
region, with residues exceeding 5 mg/kg. Four of these
stations had residues exceeding JO mg/kg during the last 5
years. 'Fish in four of the Great Lakes stations had PC3
concentrations exceeding the 5 mg/kg level and all stations
reported concentrations exceeding 0,5 rng/kg. In the
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19
Mississippi River system, the Allegheny and Ohio were the
hot spots, with seven out of th= eight stations reporting
residue concentrations in excess of 5 rr.g/kg. Thirty-one of
thirty-five stations in this river system reported residues
in excess of .15 mg/kg in the 1970-73 sampling programs.
The highest residues, often exceeding 10 mg/kg, were found
in the Allegheny, Kanawha, Curr.berland, Tennessee, and Ohio
Rivers along with stations on the Mississippi River at
Memphis,.Tennassea, and the tfisscuri River at Herman,
Missouri. Other monitoring .stations that were found to have
residue levels exceeding 5 mg/kg during the sampling periods
1970-73 included: tha Willicrcatte River on the Columbia
system; the Rouge River in the Pacific coastal drainage; the
Sacramento River in California; the Chena River tributary of
the Yukon in Alaska; and the Rio Grande, Alabama, and
Mississippi Rivers i;i the Gulf States region. Only in two
sample periods of 1972-73 ar.'d in tha current monitoring
sample's, which are still yet to be fully analyzed, has there
been a downward trend, but this occurs only in those samples
where residues are not being detected. The stations where
high residues have been noted in the past still remain rela-
tively contaminated with PCS. Unlike tha decline of DDT in
Great Lakes fish, PCS' concentrations do not show significant
changes and may trend upward in salmonids, ...."
A-31
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20
* *
Both the Hudson River (Spagnoli and Skinner, 1977) and Lake
Michigan (Humphrey _et_aK, 1976} have exhibited PCB levels In
their sportsfish that were very high end in some cases still
increasing.
The Michigan Department of Public Health recently completed
i
a study (Humphrey, H.E.B. e>t .sK, 1975) which attempted to assess
seme of the consequences of human exposure to RGB's from the '
consumption of sportsfish caught in different areas of Lake
Michigan. The study included exposed and control subjects from
five areas of Michigan bordering on Lake Michigan. Exposed study
subjects Vr-are those individuals who'censured at least 24 to 25
Ibs of Great Lakes fish per year. 'Control subjects were those
individuals who consumed less than 6 Ibs of Great Lakes fish per
year. An assessment of tha findings in the study indicates that
the most frequently recorded quantity cf fish consumed by the
study participants was in ths 24-25 Ib/yr range. The highest
record3d fish consumption over the two-year period of the study
was 180 Ib/yr, and the highest single-season consumption was 260
pounds.
Mean PCB levels in whole lake trout are reported as 18.93
ppm in 1973 and 22.91 ppm in 1974; and in coho salmon, as 12.17
A-32
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21
ppm in 1973 and 10.45 ppm in 1974. However, comparisons of PCB
«
i
levels in raw vs. cooked fish indicated that actual human expo-
sure to PCB's from fish consumption was less than might be -
expected from'the raw fish data. This is because preparation
(trimming away fatty tissue) and cooking result in a decrease in
the amount of PCB's remaining in the fish at the time it is
consumed. For example, the PCB level in cooked lake trout
consumed by the study participants ranged from 1.03 ppm to 4.67
ppm; in cooked salmon from 0.48 ppm to 5.33 ppm; and in other
cooked fish from 0.35 pprn to 2.06 ppm. These levels are decid-
edly lower than the level of PCB contamination reported in raw
trout and salmon. . .. . . .
PCB's.were found in.all blood specimens collected from the
182 study participants during the study period, including
controls. The values ranged from a mean of O.C07 ppm in blood in
the control group to a mean of 0.355 ppm in the exposed group.
Although there was a wide range of blood values for each quantity
of fish consumed, there was a highly significant correlation
between the reported quantity of Lake Michigan fish consumed and
the concentration of PCB's in the blood of study participants.
*
No annual variation in PCB blood levels in humans could be
demonstrated. The mean PCB blood values for the control" and
exposed groups did not appear to change rarkedly from 1973 to
A-33
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22
1974. In addition, abstinence from Lake Michigan fish
consumption for a"period of 90 days or more did not change the
PCB blood levels significantly. PCB blood'levels over the
abstaining period show variations, but no steady decline. In
fact, more subjects showed no change or a rise in PCB blood
levels than showed a decline during the period of abstinence.
I
The calculated quantity of PCB's ingested by eating Lake
Michigan fish averaged 46.5 mg/yr and ranged from 14.17 to 114.31
mg/yr. The calculated mean daily dose received by the exposed
group in the study was 1.7_jug/kg/day and ranged from 0.09 to 3.94
^iig/kg/day. PCB ingastion for each individual was determined by
proportioning his/her reported annual fish consumption by fre-
quency of species eaten and the cooked fish PCB levels for those
fish. The comunity average for cooked fish was used in
instances where cooked fish determinations were not available for
a study participant. Because fish consumption was found to vary
* *
from year to year, the average annual consumption for each indi-
vidual for the two baseline years of study was used in-each
case.
The exposed group experienced no observable adverse health
effects or symptoms as a result of their exposure. Though this
study suggests that the PCB consumption and blood levels observed
A-34
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23
in the study are not high enough to trigger the adverse effects
- *
experienced by the Yusho population, it does not preclude the
possibility that such levels caused effects too subtle to- detect
or effects whose latency periods exceed the period of the study.
One subject in thi? study gave birth to a normal child in
.January, 1976. A milk specimen from this individual contained 4
ppm PCS (on a fat basis), whereas the blood PCB level was 0.053
C . PCS Exposure From Hunan Milk
A nationwide survey for levels of ?C3's in human milk covering 44
States was conducted by Savage (1977). He examined 1033 samples and
detected PCB's .in. all but 5 cf the samples. Of the positive samples,
720 had trace amgunts and 309 had levels that ranged from 0,03 ppni to
15.92 ppm (fat basis). A total of 31 samples (7.3%) had PCB levels
thst were in excess of the present 2.5 pp:n (fat basis) temporary
tolerance usad by FDA for commercial milk. The mean PCS concentration
for all the samples v/as estimated to be in .the range of 1.00-1.10 ppm
(fat basis),
Although only one data point is available for PCB's in human milk from
#
a Michigan fish consumer, this level is quite high (4 ppm on a fat
basis). It rjems reasonable to assume that since this woman was an
average sports fish consumer, a sizable number of the women in
A-35
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24
Michigan who confer sports fish could produce mi ?w cnat has four
times (4 ppm vs. 1 ppm) the averge U.S. levels of PCB's. The same may
be true for other states in which sports fish consumption is similar"-
«
to that of Michigan.
A recent study (Kuwabara _et jB]_., 1978} examined the relationship
between breast feeding and PCB levels in the children of mothers occu-
pational^ exposed to PCB's. The children had ingested their mothers'
milk for 0 to 3 years. The age of the children was 0-13 years. Con-
trol subjects, Yusho patients, and cccuoationally exposed mothers were
studied for PCB blood levels and had 2.6 +_ 1.2, 4.2 _+ 1.9, and 36.8 _+
21.5 ppb, respectively. The children of the occupationally exposed
mothers hod PCB blood levels of 14.3 _+ 18.1 ppb. Thus, these children
had PCB blood levels that v;ere at least 3 times higher than were blood
levels in Yusho patients. Close examination of 59 of these children
indicates that t'-ie determining factor1 in the children's blood level
was the length of tine that the child oreast fed and not the ags of
the child when the blood levels were determined. Thus, blood levels
in children-who fed on artificial milk-is much lower than that of
their mothers' (rnothsrs 45.3 +_ 23.5, children 5.8 ^ 5.8); children who
breast fed less than three months had moderate blood levels (mothers
35.5 _+ 19.3, children 12.5^6.9 ppb); and children who breast fed for
greater than three months had higher blood levels than their mother
(mothers 21.9 +_ 13.4, children 32.8 +_ 33.3 ppb). These results
suggest that the PCB blood levels in children are much more a function
of PCB from mothers' breast milk than placental transport during
gestation. The authors further estimated that the expected
A-36
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25
exposure for adults having ncr occupational exposure was 20jjg/day
(0-33_^jg/kg/day) while children of occupationally exposed mothers
would have been exposed to 503jJg/day if their mothers' milk had-0.5
ppm PC'3's and they consumed 1 kg milk/day. No overt toxicity was
reported in the children.
RISK ASSESSMENT
Because of the lack of sufficient human data, risk assessments
s
for potential long-term tcxic effects of PCB's must be made on the
basis of animal experiments. In the absence of contradictory kinetic
or metabolic data, animal data are appropriately used to estimate
potential human risks. Because the numbers of animals used in tests
are limited, dosas above the human exposure levels are used in anirncl
studies to incraa.se.the probability of detecting potentially toxic
chamicals. Thus, it is necessary to estimate the risks to humans at
low doses by use of statistical extrapolation. Because of the inabil-
ity to observe the low end of the dose-j-esponse curve with precision,
the Interagsncy Regulatory Liaison Work Group en Risk Assessment
(1979) has recommended the use of-linear (or v;hen necessary, one-hit) -
extrapolation'from high to low doses. Of the available methods that
appear to be consistent with what is known about the biological mecha-
nism of carcinogenesis, the linear method is the least likely to.
underestimate risk. Also, linear extrapolation is the limiting case
for the multi-stage model of carcinogenesis at low doses. Because the
shapes cf dose-response curves at low doses are unknown, actual
estimates of risk are not possible. But, based on plausible
A-37
-------
26
assumptions, it generally is possible to place upper bounds on
"x .
potential human risk by use of linear extrapolation based on animal
*
data. The linear method is.used here. Upper 99% confidence bounds on
the animal response data are used to eliminate the effect of sample
size so that comparisons between experiments can be made. Use of such
upper bounds adds an additional degree of conservatism to- the
estimate.
The extent to which these estimated risks reflect true human risk
is always uncertain- In the case of PCS's, the uncertainty is greatly
compounded by the absence of toxicity data on the particular set of
FCB's that occur as residues in fish. Due to environmental 'transfor-
mation, the PCB residues found in fish are of a chemically different
/
composition than any of the industrial PCB products, though a typical
PCB residue in fish resembles the Aroclor 1254 mixture more closely
than It doas other Aroclors (Zitke jet aU, 1972; Veith, 1975). AIT
the animal toxicity data represent the "effects of one of. the indus-
trial PCB products; no toxicity studies have besn performed using the
PCS residue that actually occurs in fish. For this reason, it is
uncertain that the available toxicity data accurately represent the
toxicity of the PCB mixture ingested by humans who consume fish. The
fairly close resemblance of such residues to Aroclor 1254 perr.its some
reliance to be placed en data derived from studies of that PCB
product, but ths chemical difference between even that product and
actual fish residues introduces an additional element of uncertainty
into the risk assessment.
A-38
-------
21
Data from the NCI bioassay program in :which Aroclor 1254- was fed
to Fisher rats are presented in-Table 5 to show the numbers of total
malignancies, liver carcinoma plus adenomas, and hematopietic effects
in males and females at various feeding levels. Similar data are also
presented in Table 5 for the feeding studies of Kinbrough using female
Sherman rats fed 100 ppm Aroclor 1260.
Based on the toxicity data in Table 5 and the exposure data in
s .
Trible 4, tha upper confidence limits (99%) on lifetime risks for
career in eaters of the 12 fish species of commercial interest at the
5'Jth snd 90th percentiles of consumption have been calculated and are
prssented in Table 6. In addition, the lifetime risk for consumers of
sportsfish in Lake Michigan at the 50th and 90th percentile of con-
sumption are presented. These risks would probably approximate those
o
of sportsfish consumers in other areas of the country having PCE-
contamination, but for which residue data are not available. Upper
' -
limits en estimated risks have been computed from the NCI data on
*
tots! mal ignanjiss for males plus females, liver carcinoma plus
adenomas in males plus females, and on hematopietic in males plus
fe.iiales. Estimated risks similarly computed from the Kimbrough data
are also presented in Table 6. The various estimated risks shown are
based on mean PCB levels in commercial fish, assuming no tolerance, a
tolerance of 5 ppm, 2 pprn, and 1 ppm. Risk for sports fishermen was
only calculated assuming no tolerance, because tolerances have no
relevance to such exposures. Because the relative susceptibilities of
havens and tcsv animals to the chronic effects are unknown, it is not
certain whether tha data in Table 6 over- or underestimate human
risks. The deta do show, howaver. remarkable agreement, indicating
A-39
-------
28
that the various rat strains used react similarly to PCB carcinogenic
insult. The relative effects of exposure reduction can be seen and
increased risk associated with sportsfish consumption in Michigan
* '
(and, presumably, in other areas having similar contamination
problems) is apparent.
Multiplication of the size of the population at risk by the risk
\
estimates found in Table 6 yields the number of extra cases of car-
c-noma per year; these data are presented in Table 7. The assumption
was made that the risk is evenly distributed over a 70-year lifetime.
A tolerance of 5 ppm appears to reduce cancer risk about 8-10£ from
that expected with no tolerance; a tolerance of 2 ppm appears to
reduce risk about 32-38%, and reducing the tolerance to 1 ppm appears
to reduce risks to 55-615S of the cancer risk expected in the absence
f .
of eny'tolsrence. Furthermore, the Laka Michigan sports fish con-
sumers have a 12-14 fold increased risk compared to the general U.S.
population.
It should be noted that the possible human risks due to tha
effects of PCS's on the reproductive system an^ offspring cannot be
ignored. Exposure to PCB's from human milk also imposes an additional
burden on the infant, which burden has yet to be assessed. Certainly,
the infant who is breast feeding will consume higher levels cf
PCB's/kg/day than tha general population. Added to the nationwide
human milk PCB burden would be the increased levels of PCB's that
would occur in the milk of consumers of sportsfish.
A-40
-------
29
estimating risk from exposure during gestation and'neonatal
growth is very difficult. The toxicological data have not been
developed, and the methodologies for computing life-time risks from
exposure to a substance only during a short period of life have not
been developed. It is reasonable to predict that children exposed in
such a fashion may suffer an increased cancer burden from PCB'sa
especially if dietary contamination continues after childhood and
throughout life; thus, the risk estimates shown in Table 6 may
underestimate risk in years to come. -
A-41
-------
Table 1: Total Diet Studies-American Teenage Male
Percent of composites containing PCB's
Food class composites
Dairy
Fiscal pro-
Year ducts
n/i
1972 6
1973 . 10
1974
1975
(1st -
half)
Meat, Grain & Lccjume Root
fish a cereal veg.e- voge-
poultry products Potatoes tables tables
47 13 . -
46 6 63
33 17 3
' 43
40
. ' _ Oils,.
fats . Sugars
Garden & short- and
fruits ening adjuncts
3-17 6
o
3
Source: Oclinek and Corneliusson (1976}
A-42
-------
Table 2: Estimates of Daily PCB Intakes
(Total Diet Study-Teenage Male)
Fiscal
year
1971
1972
1973
1974
1975*
1976*
1977*
Average Daily Intake
of PCB'sa
Total diet Meat-fish-poultry food class
(ug/day) (ug/day)
15.0 'X
12.6
13.1
8.8
8.2
8.5
8.7
9.5
9.1
8.7
8.8
8.2
7.9
8.1
alowar .limit of quantitative reporting = 0.05 ppm with
analytical method employed.
*Jelinek (1979) personal corrmur.ication.
A-43
-------
Table 3: Mean PC3 Levels In FDA 1978-1979 Domestic Survey by Species of Interest
Assuming 5 ppm Assuming 2 ppm Assuming 1 ppm
Assuming No Tolerance* Tolerance . Tolerance Tolerance
Species of Interest
Carp
Catfish
Buffalo
Freshwater Trout
Sea Trout
Bass
Chubs
Bluefish
Scup (Porgy)
' Drum
Mackerel
All Others
*For assumed tolerances, PCB values exceeding the tolerance were oliminted in calculating the mean,
A-44
Mean
(ppm)
1.10
1.70
0.50
1.36
0.56
1.28
1.14
0,53
0.72
0.19
0.53 .
0.26
N -
54
295
36
' 07
10
15
19
23
10
12
21
206
Mean
(ppm)
0.90
1.19
0.50
1.28
0.56
1.28
1,14
0.53
0.72
U:49
0,53
0,26
N
52
281
36
10
15
19
23
10
12
.21
206
Mean
(ppm)
0.68
0.73
0.43 .
0.76
0.56
0.77
0.96
0.44
0.72
0.49
0.53
0.24
N
46
219
35
58
. 10
11
17
22
l.P
12 :
21
204
Mean
(ppm)
0.54
0.38
\.
0.30
0.37
0.27
0.27
0. 58
0.37
0.53
0.32
0.28
0.22
N
38
150
31
40
8
10
9
20
8
10
17
201
-------
Table 4: Intake of PCB's from Fish for Eaters of Soccies of Interest (3939/25,947)
Assui.ii ng* Assuming
Mo Tolerance Tolerance
= 5 ppm
Assuming
Tolerance
- Z ppm
Assuming
Tolerance
= 1 ppm
Intake at 50th percentile -
ug per day
PPM of diet**
ug per kilogram of body
weight
Intake at 90th percentile -
ug per day
PPM of diet
ug per kilogram of body
weight***
8.46
.0056
.12
22.1
.0147
.32
7.57
.0051
.11
20.1
.0135
.29
5.59
.0037
.00
14.9
.0099
.21
3.30
.0022
.05
9.22
.0061
.13
* For assumed tolerances, PCB values exceeding the tolerance were eliminated
** Assumed 1500 grams daily intake
A-45
-------
Table 5: Animal Data Used for Risk Extrapolation to Humans
Dose of Aroclor fed in pprn
Animal Studies 0 25 50 100
liCI Eioassay - Fischer
Rats fed Aroclor 1254
Total Malignacies
Males
Females
Combined
Live'- Carcinoma £ Adenomas
f-^ales
remales
Combined
Males
Fer.alss
Combined
5/24
4/24
9/43
0/24
0/24
0/4?
3/24
4/24
7/48
2/24
13/24
15/48
0/24
0/24
0/43
2/24
6/24
8/43
9/24
p/24
17/43
1/24
1/24
2/48
5/24
5/24
11/48
12/12
9/24
21/48
2/24
2/24
4/48
0/24
6/24
15/43
Kimbrough - Female
Sherman Rats fed
Aroclor 1250
Hesatocellular Carcinomas 1/173 26/134
A-46
-------
Table G: Upper Confidence Limits (99%) on Lifetime Risks* of Cancer in Caters of Fish Species of Interest
Animal 50th Percentilc Eaters
Studies on v.'hich
risks .ire based Assuming Assuming Assuming Assuming
No Tolerance Tolerance Tolerance Tolerance
Lake'** = 5 ppm - 2 p;vi: = 1 pom
USA Michigan
^Kimbrough - Rats
Liver Carcinoma 1.3 18.1 1.2 0.8 O.G
>
NCI Bioassay - Total
Malignancies for
M,ile"ft Female 4.1 50.0 3.7 2.7 1.6
NCI Bioassay - Liver
Carcinoma & Adenomas
for Male A 'Female 0.9 12.75 0.9 O.G 0.4
*"'NCI Bixi.issay .
llematopiotic
for. Male £ Female 2.7 38.25 2.4 1.8 1.1
90lh Percent! le Eaters
Assuming Assuming Assuming
No Tolerance Tolerance Tolerance
Lake** - 5 ppm - 2 ppm
USA. Michigan
3.4 41.4 3.1 2.3
10.6 129.2 9.8 7.2
2.5 30,5 2.3 1.7
7.0 OS. 3 6.5 4.7
Assuming
Tolerance
= 1 pptn
1.4
4.4
1.0
2.9
* All risks arc lifetime risks computed as rates per '00,000 of the population at risk.
**Risk calculated for Lake Michigan sportsfish eaters who .consume an average of 1.7jig/kg/day PCB
or 3.9jug/kcj/dny nt the 90th percent.Me. Risks in other area's having similar sportsfish consumption
and PCB contamination are probnbly similar.
A-47 -
-------
Table 7: Upper Confidence Limits (99£) on Number of" New Cancers per Year in Caters of Fish Species of Interest
Animal 50th Percentile Eaters 90th Percent! le Eaters
Studies on which
risks are based Assuming Assuming Assuming Assuming
No Tolerance Tolerance Tolerance Tolerance
Lake** = 5 ppm = 2 ppm = 1 ppm
USA Michigan
^
Kimbrough - Rats
Liver Carcinoma 6.2 10.4 5.8 3.8 2.4
NCI Bioassay - Total
Malignancies for
Male A Female 19.6 32.0 17.6 12.9 7.6
NCI Bioassay - Liver
Carcinoma & Adenomas
for Male & Female 4.3 7.2 4.2 2.9 2.0
NCI Bioassay
Hematopoietic
for Male A Female 12.9 21.6 11.4 0.66 5.3
Assuming Assuming
No Tolerance Tolerance
Lake** = 5 ppm
USA Michigan
16.3 23.4 14.7
50.6 73.1 46.8
12.0 17.3 10.9
33.4 40.3 31.0
Assuming Assuming
Tolerance Tolerance
= 2 ppm = 1 ppm
10.0 6.7
34.3 21
0.0 4.7
22.5 13.8
* All risks are the increased number of cancers per year for the population at risk (15.2% of U.S. population)
considering a 70 year life span.
**Risk calculated for Lake Michigan sportsfish eaters who consume an average 1.7jig/kg/day PCD
or 3.9jig/kg/day at the 90th percontile. (1,000,000 people assumed exposed) Risks should be
similar for sportsfish eaters in other areas; but data, not available to make estimate.
-------
REFERENCES.
45-1 Allen, J.R. and Barsotti, D.A. (1976). The. effects of transpl acental and
narnnary movement of PCBs on infant rhesus monkeys. Toxicol.
6:332-340.
45-2 Allen, J.F. and Norback (1976). Pathobiological response of primates to
polychlorinated biphenyl exposure. Proceedings of the Nation:
Conference on Polychlorinated Biphenyls (Nov. 19-21, 1975, Chic a go,
111.) EPA -560/6-75-004.
45-3 Schn, A.K., Rosenwaike, I., Herrmann, N., Grover, P., Stellman, J. and
O'leary, K. (1976). Melanoma after exposure to PCB's. New England
Journal of Medicine 295, 450.-
'45-4 Eahn, A.K., Grover, P., Rosenwaike, I., O'Leary, K. and Stellnan, J.
(1377). PCS? and melanoma. New England Journal of Medicine 295,
^5-5 Earsotti, D.A., Parlar, R.J., and Allen, J.R. (1975). Reproductive
dysfunctions in rhesus monkeys exposed to low levels of poly-
chlorinated biphenyls (Arochlor 124S). Food and Cosmetics
Toxicology
^o-o Celandra, J.C. (1976). Summary of toxicological studies or. commercial
PCS's. Proceedings of the National Conference on Polychlorirated
Bi_phsnyTs"TfoV' 13-21, 1975, Chicago, 111.) EPA-56C-/6-75-QC4,
35-42.
45-7 Cordle, F., Corneliussen, P., Jelinek, C., Hackley, B., Lehman, R.,
Mclaughlin, J. Rhoden, R. 2nd Shapiro, R. (1973). Hu-.ir, exposure
to polychlorinated biphenyls and polybrcminated biphenyls.
Environmental Health Perspectives 24, 157-172.
45-8 r,H£Wj (1S75) Final Report of Subcornmittee on Health Effects of
Polychloronated Siphenyl and Polybromonsted Biphenyl s.
^--9 Humphrey, H.E.B. (1976). Evaluation of changes of the level of
polychlorinated biphenyls (PCB) in human tissue. Final Resort
on FDA Contract 233-73-2209.
45-10 Industrial Bio-Test Laboratories, Inc. (1971). Reports to Monsanto
Company. Two-year chronic toxicity with Arochlor 1242, 1254, and
1250 in albino rats. Unpublished reports, November 12, 1971.
1ST Mo. 57293.
45-11 ito, N., Nagasaki, H., Aral, M., Makiura, S., Sugihara, S., and Hiraco, K.
(1973). Hisopathologic studies on liver tumorigenesis induced by
mice by technical polychlprinated biphenyls and its promoting .effect
on liver tumors induced by benezene hexachloride. Journal of the
National Cancer Institute 51, 1637-1646. ! '.
. A-49
-------
45-12 Jelinek, C. and Corneliussen, P.E. (1976). Levels of PCBs in the U.S.
food supply. Proceedings of the National Conference on
Polychlorinated Biphenyls (Nov. 19-21, 1975), Chicago, 111.)
EPA-560/6-7b-004, 147-154.
45-13 Johnson, R.D. and Maske, D.D. (1977). Pesticide and Other Chemical
Residues in Total Diet Samples (XI). Pesticide Monitoring
Journal 11, 115-131.
45-14 Kimbrough, R.D., Linder, R.E., Burse, V.W. and Jennings, R.W. (1973).
Adencfibrosis in the rate liver, with persistence of poly-
chlorinated biphenyls in adipose tissue. Arc'nivas of Environmental
Health 27, 390-395. ~~
45-15 Kimbrough, R.D. and Linder, R.E. (1974). The induction of adEnofibrcsis
and hepetonas of the liver in mice of the BALB/c J strain by poly-
chlorinated biphenyls (Aroclcr 1254). Journal of the National
Cancer Institute jj3_, 544-552.
45-15 Kimbrough, R.D., Squire, R.A., Linder, R.E., Strandburg, J.D., Monteli,
R.J., and Burse, V.W. (1975). Induction of liver tunors in Sherman
strain female rats by polychlorinated biphenyl Arcclor 1260.
Journal of the National Cancer InstUute _55> 1453-1459.
45-17 Kuratsune, M., iiasuda, Y. and Nagayana, J. (1976). Some of the recent
findings concerning Yusho. Proceedings of the National Conference
on FCBs. EPA-560/5-75-004, pp. 14^297'. "
-5-13 Kuwabara, K., Yakushiji, T., K'atanabe, I., Yosnida, S.5 Koyana, K.,
Kunita, K., and Mara, I. (1978). Relationship between breast
feeding and PCS residues in blood of the children whose mothers
were occusatTonally exposed to FCBs. Ir,t. Arch of Occup. Environ.
Health 4l':189-197.
45-19 Linder, R.E., Gainas, T.B., and Kimbrough, R.D. (1974). Tne effect of
polychlorinated biphenyls on rat reproduction. Food and Cosmetic
Toxicology 12, 63-77).
45-20 Monsanto (1975). Industrial Bio-Test Laboratories, Inc. Reports.
Histopathological evaluation of additional liver sections.
March 24, 1975. Unpublished reports, Monsanto Co., St. Louis,
Missouri.
45-21 National Marine Fisheries Service (1976). Compendium of PCS data.
NOAA, U.S. Dept. of Conferee, Washington, D.C.
45-22 .National Institute for Occupational Safety and Health. (1977).. Criteria
for a recormended standard.. .occupational exposure to poly-
chlorinated biphenyls (PCBs). DHEW (N'ICSH) Publication No.
77-225.
A-50
-------
^5-23 NCI (National Cancer Institute) (1978). Bioassay of Aroclor 1254 for
possible carcincgenicity. Carcinocenesis Technical Recort Series
No. 38, CAS No. 27323-1S-8 NCI-C3-TR-33. (See Ref. 47)
45-24 N'agayama, J., Y. Msuda,.and M. Kuratsune, (1975). Chlorinated
Dibenzofurans in Kanechlors and Rice Oils Used by Patients with
Yusho, Fukuoka Octa Ned, Vol. 56, No. 10, 593-599.
45-25 Spagnoli, J.J. and Skinner, L.C. (1977). PCB's in fish from selected
waters of New York State. Pesticide Monitoring Journal 11, 6S-87,
<5-25 Veith, G.D. (1975). Baseline concentrations of PC3s and DOT in Lake
Michigan Fish, 1971. Pest Monitoring Journal 921-29.
45-27 ',,'3lker, C.R. (1975). The occurence of PC8 in the National Fish and
Wildlife Monitoring Program. Proceedings of the National Con-
ference on Polychlqrinated Biohenyls ('lev. 19-21, 1975, Chicaoc,
TTT7)EPA-560/6-75-004, 161-175.
i"r5-2S Zitko, V., Kuntzinger, 0., and Choi, P.K.K. (1972), Contamination of the
Bay of Fundy-Gulf of Maine Area with PCSs, PCTs, Chlorinated EBF
end DBD, Environ. Health Perspect. 1:47-50.
A-51
-------
APPENDIX B
PCB Hot Spot Dredging Program
Upper Hudson River, New York, Rescoping Report
MPI, February, 1981. Draft PCB Hot Spot Dredging Program, Upper Hudson
River, New York, Rescoping Report. Submitted to New York State
Department of Environmental Conservation, Albany, New York.
-------
MALCOLM PIRNIE, INC.
Consulting Environmental Engineers
WAPORA N. Y.
APR 11981
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Date:
Re: _
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301/587-5355
D 500 South 22 St. (Suite 212), Birmingham, Ala. 35233
205/322-0513
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305/923-9131
31 (9 (
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by
B-l
-------
HUDSON RIVER PCB RECLAMATION PROJECT
SCOPING REPORT
MARCH 1981
BACKGROUND
This rescoping of the PCB hot spot dredging project has
been prompted by the limited funding available to undertake
the work. The cost of the original 40 hot spot dredging
program, including construction of the containment site and
removal of remnant deposit areas 3 and 5 (remains of the
former Fort Edward Pool deposits above Fort Edward) was an
estimated $40 million. Total funds available for the project
at this time are $26.7 million, and the purpose of this review
is to identify the most beneficial and cost-effective combin-
ation of project elements which can be completed for this
amount.
This report briefly describes the original hot spot
dredging program as evaluated in the Draft Environmental
Impact Statement, New York State Environmental Quality Review
(Draft EIS, New York SEQR), as well as associated actions
which include relocation and containment of contaminated New
York State Department of Transportation (DOT) dredge spoil
material and nearby dumps. It then presents a discussion of
discrete elements of the $40 million project, criteria for a
rescoped project, a proposed reduced scale program.
BRIEF DESCRIPTION OF ORIGINAL PROJECT
The original project, as presented in the Draft EIS,
included six components directed toward reducing the impact of
PCB on the Hudson River, its biota, and the surrounding Hudson
River Valley. These components we.-*:
B-2
-------
o Dredging of 40 hot spot"-1-" areas in the river bed
with containment in a secure upland site.
o Design and construction of a secure upland contain-
ment site capable of long-term isolation of contami-
nated material.
o Excavation of remnant deposit areas 3 and 5, located
above the former Fort Edward Dam site, and removal
to the upland containment site.
o Provision for containment of material from three
PCB-contaminated dump sites in the Fort Edward
area - Old Fort Edward, Fort Miller and Caputo -
should removal be found more suitable than in-place
containment.
o Provision for containment of contaminated material
from three DOT dredge spoil areas - Spoil Area 13,
Site 212 and Site 204 Annex.
o Destruction of the recovered PCB at such time as a
technically and economically feasible procedure
becomes available.
If relocation of the above mentioned dump and spoil area
material were to take place in conjunction with the dredging
of all 40 hot spots and the removal of remnant deposit areas 3
and 5, almost half of the PCB estimated to be in the Hudson
River and adiacent land areas would be permanently contained.
(See Table 5.; However, this figure includes the movement of
DOT spoil areas and highly concentrated dump materials, and
therefore does not represent the reduction of PCB in the river
itself. Dredging of the 40 hot spots and excavation and
movement of all of remnant deposit areas 3 and 5, would result
in a 54 percent reduction in the mass of PCB contained in the
bed and banks of the Upper Hudson. The bed and banks of the
Hudson River, as defined here, include all of the hot and cold
areas in the Upper Hudson River (bed) and the remnant deposits
[1] Hot spots have been defined as areas of PCB contamination
equal to or greater than 50 |jg per g.
B-3
-------
(banks). Dredging all of the 40 hot spots would alone result
in a 49 percent reduction in the mass of PCB in the bed of the
Upper Hudson River and a 33-35 percent reduction in the mass
of PCB in the bed and banks of the Upper Hudson River. A
reduction in the scope of this project would result in a
corresponding reduction in the amount of PCB removed from the
river. This relationship is not linear, and the revised
project will be designed to recover the greatest mass of PCB
potentially subject to loss to the water column for the funds
available.
Table 1 presents an estimate of the cost of the original
40 hot spot project. The $40 million cost indicated was based
on construction of the containment site in 1981, and a two
year dredging program in 1982 and 1983.
ORIGINAL PROJECT
General
The proposed program was to have a three year duration.
The first year included site construction and probing and
sampling of lower pools. The second year included dredging
the 20 hot spots in the Thompson Island pool, removal by
truck, partially or completely, of the Area 3 and 5 remnant
deposits, and subsequent covering of the required portion of
the containment area. In the third year, the lower pools were
to be dredged, and the remainder of the containment area
covered and sealed. In addition, the nonpermanent earthen
basins on the site were to be razed and these areas regraded.
In this section each element of the program will be
described. The cost associated with each is presented in
Table 1. A location map is presented in Plates 1 and 2.
Data Used
The quantities of contaminated volumes to be removed and
associated PCB masses for each of the hot spots are those
computed by Malcolm Pirnie, Inc. (MPI 1978).
B-4
-------
TABLE 1
ESTIMATED COSTS FOR ORIGINAL 40 HOT SPOT DREDGING PROGRAM
(All costs in thousand dollars)
Phase
Site Construction
Cover Costs
1981
(3)
1982
(4)
1983
(4)
(1)
$4770
$ 789
Site Modifications
After Closure( '
Thompson Island,.,
Pool Dredging
Remnant Deposits
Removal
Lower Pool Hot Spots
Dredging
Lock 6 -
Lock 5 -
Lock 4 -
Lock 3 -
Lock 2 -
Material Rehandling
Sub-Total
$ 868
429
6534
1670
221
$4770
Contingencies 480
Engineering Design 278
Field Engineering &
Construction Administration 384
Legal & Administrative 69
Totals By Year $5981
Three Year Total
Scientific, Engineering,
Monitoring &
Administrative Costs
9/76-3/80
Scientific, Monitoring
& Administrative
Estimated 4/80-3/83
Project Total
$9214
2525
930
1062
257
$13,988
Total by Phase
$ 4770
1657
429
6534
1670
844
2826
1329
1371
1457
420
$9323
2624
1018
1493
293
$14,751
$23,307
5629
2226
2939
619
$34,720
$34,720
3,480
1,800
$40,000
Notes:
(1) Includes site work costs for all phases, except site modifications
after closure and cover costs.
(2) Includes south dike channel, additional swale drops, and razing and
regrading the roughing & storage pond, surge pond and the treatment
plant basins.
(3) Escalated 13.2 percent from third quarter 1980 to mid-1981.
(4) Escalated 24 percent from 1979 to 1980, and 10 percent/year from 1980.
(5) Includes site acquisition costs.
B-5
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Related Studies
More detailed descriptions of each of the project elements
and their costs can be found in the following previous reports:
o Phase I Engineering Report, Dredging of PCB Contam-
inated Hot Spots, Upper Hudson River, NY, Malcolm
Pirnie,Inc. (December 1978).
o Design Report, PCB Hot Spot Dredging Program Contain-
ment Site, Malcolm Pirnie, Inc. (September 1980).
o Dredging System Report, Program Report No. 2, PCB
Hot Spot Dredging Program, Upper Hudson River, NY,
Malcolm Pirnie, Inc. (September 1980).
o Draft Environmental Impact Statement, PCB Hot Spot
Dredging Program, Upper Hudson River, NY, Malcolm
Pirnie, Inc. (September 1980).
Containment Site
The containment site, referred to as Site 10 in earlier
reports, is situated on a 250 acre parcel of land located
approximately 2.5 miles south of the Village of Fort Edward,
in the Town of Fort Edward, in Washington County, New York.
(See Plate 3).
The site's major components are:
o Containment Area
o Roughing and Storage Pond
o Surge Pond
o Water Treatment Plant
o Pump Station
o Leachate Collection System
o Access Road
o Storm Water Drainage System
o Chemical Feed System
o Appurtenances
Containment Area - The containment area is an earthen
basin bisected by a cross dike. It occupies approximately 63
acres at its maximum water surface and its total containment
B-6
-------
volume at the maximum water surface is 2,260,000 cu yds. This
volume is sufficient to hold all of the 40 hot spots, remnant
deposit areas 3 and 5 and the DOT spoil areas.
The containment area is designed for long term encapsula-
tion of PCB-contaminated materials, and will therefore be
capped with a clay cover during each season of dredging.
Roughing and Storage Pond - The roughing and storage pond
(R&SP) is an earthen basin with a maximum water surface area
of approximately 12 acres.
After the slurried dredge material is pumped into the
containment area, weir overflow is transported via pipeline to
the R&SP. The primary purpose of this basin is to ensure
efficient sedimentation near the end of each dredging season
as the effective overflow rate in the containment area de-
creases . The R&SP also provides protection for the subsequent
treatment units from any upsets in the containment area which
might lead to transient escape of dredged material.
A small portable dredge will be operated to recycle
settled dredged material back into the containment area.
The R&SP is not a permanent containment unit. At the end
of the dredging program, all of the contaminated material in
the R&SP will be relocated to the containment area and the
pond will be filled in and regraded.
Surge Pond - The surge pond is an earthen basin with a
maximum water surface area of 2.4 acres. This pond receives
weir overflow from the R&SP. Its purpose is to buffer the
treatment plant units from surges in the dredging process and
to provide a convenient, sediment-free point for treatment
feed and recycle supply pump suctions if a recycle dredging
procedure is implemented. A detailed discussion of dredging
options is presented in the Containment Site Design Report.
Water Treatment riant - The water treatment plant consists
of two earthen basins, Lhe flocculation basin and the settling
basin, with maximum water surface areas of 0.1 and 1.0 acres,
B-7
-------
respectively. The plant has a capacity of 13 million gallons
per day (mgd) and consists of coagulation, flocculation and
sedimentation units. The purpose of the water treatment plant
is to reduce PCB concentration in the dredge return flow
before discharge to the river.
The water treatment plant is expected to achieve effluent
suspended solids less than 4 milligrams per liter and turbidity
less than 10 NTU with proper chemical doses. The average PCB
concentration in the discharge is expected to be in the 10-20
microgram per liter range.
Pump Station - The pump station consists of three mixed-
flow pumps each with a capacity of 4500 gallons per minute
(gpm). One of the three pumps functions as a standby. The
pump station's function is to provide a reasonably constant
influent feed to the water treatment plant.
Leachate Collection System - The leachate collection
system is a network of perforated drainage piping laid in
gravel-filled, filter-cloth-lined collection trenches at the
base of the containment area. The bottom of the containment
area is sloped to transmit flow towards the trenches.
The leachate collection system will be utilized in two
phases: short-term dewatering and long-term percolation.
A piping system connects the drainage system to a dis-
charge point at the Hudson River.
Valves, collection and sampling wells, and a flow meter-
ing and monitoring manhole are provided to determine the
quantity and concentration of PCB in the leachate. Discharge
to the Hudson River will only be permitted if the observed
leachate quantities and concentrations will have no adverse
impact on the River. If river discharge proves unacceptable,
the leachate will be stored in-place and periodically collected
and treated.
Stormwater Drainage System - The stormwater drainage
system will intercept and convey stormwater runoff that would
B-8
-------
have directly affected the containment site. Precipitation
falling on the containment site, and on the watershed north of
the containment site, will be transported by the drainage
system to the Hudson River.
The components of the drainage system include a combina-
tion of swales, open channels, and closed conduits.
Access Road - An access road will be provided between
Route 4 and the chemical feed building. This roadway will
permit access to tank trucks delivering bulk chemicals, as
well as access and parking for contractor, engineer and DEC
personnel.
Chemical Feed System - The pumps, piping, tanks and
dilution water needed for the chemical feed system for the
treatment of the dredged slurry will be housed in a chemical
feed building.
Appurtenances - Also including in the construction site
requirements are electrical services, fencing, seeding, clear-
ing and grubbing of wooded areas and monitoring wells.
Thompson Island Pool
The Thompson Island Pool is located between the Thompson
Island Dam and Rogers Island. Th« areas to be dredged are the
20 identified hot spots (including four above Lock 7) with a
volume of approximately 645,500 cu yds and 105,800 Ibs of PCB
(see Table 2).
Under the original program, the Thompson Island Pool hot
spots were to be dredged in the first dredging season.
Lower Pools
Under the original program, the second season was to
consist of dredging the five lower pools:
o Lock 6 pool
o Lock 5 pool
o Lock 4 pool
B-9
-------
TABLE 2
REMOVAL VOLUMES AND MASS OF PCB
PROPOSED FOR MOVEMENT TO CONTAINMENT SITE
UNDER THE ORIGINAL PROGRAM
Volume to be
PCB
Concentration
in Dredged
Hot Spot
Number Location
1-4 Above Lock 7
5-20 Thompson Island
Pool
21-27 Lock 6 Pool
28-35 Lock 5 Pool
36 Lock 4 Pool
37 Lock 3 Pool
38-40 Lock 2 Pool
Total
Remnant Deposits (maximum removal
Area 3
Area 5
Total
Dumps (Non- secure Landfills)
Old Fort Edward
Fort Miller
Caputo
DOT Spoil Areas
Spoil Area 13
Site 212
Site 204 Annex
Total
Removed , *
(cubic yards K '
22,800
622,700
88,900
296,700
134,200
137,800
149,600
1,452,700
volumes)
160,900
51,600
212,500
1,000
7,400
200 1
8,600 328
191,000
77,000
3,000
271,000 35
1,944,800 574,
PCB Mass
(pounds )
900
104,900
4,900
33,700
5,000
11,700
8,800,,,,
169,900V"'
18,500
22,700
Material
(ua/g)
24
96
31
65
21
48
33m
average=67v '
66
250
41,200 average= 110
208,000
119,000
,130-10,000
,100-337,000
25,000
10,000
300-700
,300-35,700
500-583,800
(1) The dredged material volume and concentrations are calculated using
a 36 inch removal depth which includes an overcut of essentially
uncontaminated material. Contract"31 incentives to limit depth of
cut to 24 inches could reduce removal volumes and increase
concentrations.
(2) The total mass of PCB in the bed of the Upper Hudson River is estimated
to be 347,200 Ib. The remaining 177,300 Ibs of PCB are present in "cold
areas" with PCB concentrations less than 50 pg/g.
Sources: Weston (1978) MPI (1978) DEC (March 1980)
Estimates rounded to nearest 100 cubic yards or pounds
B-10
-------
o Lock 3 pool
o Lock 2 pool
The removal volumes and associated masses of PCB for each
of these pools is listed in Table 2.
Remnant Deposits
The remnant deposits are PCB-contaminated areas adjacent
to the Hudson River upstream of the former Fort Edward Dam.
These areas are the remains of 150 years of deposition behind
the dam, exposed as dry land following dam removal in 1973.
Much of the deposited material has washed downstream; those
areas which remain have been designated remnant deposits.
Under the original project remnant deposit areas 3 and 5
were to be partially or completely removed and placed in the
containment site during the first season of dredging. Area 3
has a complete removal volume of 160,900 cu yds containing an
estimated 18,500 Ibs PCB. Area 5 has a complete removal
volume of 51,600 cu yds containing an estimated 22,700 Ibs of
PCB.
DOT Spoil Areas
Thre^ DOT spoil sites, containing a total of 271,000 cu
yds of material and approximately 35,000 Ibs PCB (average
concentration 50-100 (jg per g) were proposed for movement to
the containment site under the original program. This is
material that has already been removed from the river, top
dressed and seeded. The containment site was designed to have
capacity for this material, though its movement was neither
evaluated in the draft EIS, nor considered to be a part of the
hot spot dredging program.
Dump Sites
Seven dumps in the Fort Edward area contain capacitor
wastes and other concentrated PCB materials. Under the origi-
B-ll
-------
nal program, an area was to be provided for the contents of
the Old Fort Edward, Fort Miller and Caputo dumps (total
8,600 cu yds; 328,100 - 337,000 Ibs PCB) in a segregated cell
at the containment site. Movement of the dumps was not a
component of the hot spot dredging program, was not evaluated
in the draft EIS, and was not included in the cost estimates
for the hot spot dredging project.
CRITERIA FOR RESCOPING
General
A preliminary review of the cost summary for the original
40 hot spot project shows that in order to meet the budget
constraints major elements of the project will have to be
deleted. Therefore, a set of criteria for inclusion in the
rescoped project were defined. The major criteria discussed
in this section are:
o Maximization of PCB removal from the Hudson River
o Program Performance
o Cost-Effectiveness
o Wetlands Avoidance
o Flexibility
Maximization of PCB Removal from the Hudson River
The main objective of the project is to stabilize the
maximum amount of PCB-contaminated material thereby minimizing
its uncontrolled migration. Because the remnant deposits, DOT
spoil areas and dumps are more stabilized than the in-river
PCB-contaminated material, this objective will be best realized
by maximizing the PCB removal from the hot spots in the Hudson
River.
Program ierformance
The rescoped project maintains the same level of control
on performance of the dredging and return flow treatment
B-12
-------
systems, and containment site design criteria as was incorpo-
rated in the original hot spot dredging program. Cost reduc-
tions have been achieved through elimination of specific
project elements. The quality of design and operational
controls has not been relaxed.
Cost-Effectiveness
The priority of pools for dredging has been evaluated by
developing an associated cost per pound of PCB removed per
pool for the dredging, transport and treatment required.
Pools are prioritized for removal beginning with those which
have the lowest unit cost for PCB removal and containment.
This results in concentrating dredging efforts on the most
readily accessible and most highly contaminated pools.
Wetlands Avoidance
PCB which is contained in wetland sediments is, in effect,
stabilized in place by root systems, and is, therefore, less
subject to flood scour losses, though ice scour may result in
some erosion of contaminated material. Wetlands in the river
did not experience significant erosion during the 100-year
flood in 1973. Some sediment PCB may be dislodged or taken up
by burrowing organisms, but this mechanism occurs throughout
the Upper Hudson. Recent sampling of hot spot 28, the most
highly contaminated wetland in the river, found above-ground
leaves and stems of wetland plants to average 1-4 parts per
million PCB (Buckley 1981). Though contaminated to some
degree, wetlands in the river offer cover, brooding areas, and
food for a variety of resident and migratory wildlife species.
Biologists from DEC, MPI and the Boyce Thompson Institute have
noted the biological value of these wetlands, and recommended
that they not be removed. Dredging efforts *.;ill be concen-
trated on the less stable, and less biologically productive
hot spots. Using this criteria, hot spots 25, 28, 35 and 40
3-13
-------
have been identified as containing significant wetlands and
hence have been given a low priority for removal.
THE RESCOPED PROJECT
General
Using the above stated criteria the following modifica-
tions were made to the original project.
o Deletion of remnant deposit relocation.
o Provision of top dressing and fencing for remnant
deposit Areas 3 and 5.
o Elimination of provision for the containment of PCB
contaminated dumps.
o Reduction of number of hot spots to be dredged.
o Reduction of capacity at the containment site,
resulting from the above reductions in volumes of
material to be encapsulated, as well as a better
definition of materials handling requirements at the
site.
o Reduction in the scope of research studies.
This section will discuss these modifications, and detail
the elements of the rescoped project.
Remnant Deposits
Until it is demonstrated that the remnant deposits are
indeed leaching PCB, these deposits will be considered more
stable than the hot spots. No remnant deposit removal is
recommended at this time.
Top dressing and fencing of Areas 3 and 5 has been sug-
gested as a means to minimize volatilization and public
access.
It should be noted that a proposal to reconstruct the
Fort Edward Dam is under consideration. Reestablishment of
the Fort Edward Pool may affect the stability of the remnant
deposits requiring consideration of capping or other measures
at that time.
B-14
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DOT Spoil Areas
The USEPA (1981) has advised that not all of the DOT
spoil areas have been covered properly in accordance with the
Toxic Substances Control Act. Although funding is not included
in this program for the removal and transport of these areas
to the containment site, the containment area has been designed
under the rescoping project with an excess capacity that could
be used to accommodate the DOT spoil areas.
Dump Sites
Under the September 23, 1980 agreement between DEC and
the General Electric Co., responsibility has been delegated to
General Electric and others for the remediation and long-term
maintenance of these dumps. Therefore, all provisions for
these dumps have been eliminated under the rescoped project.
Hot Spot Dredging
The reduced budget for the hot spot dredging program
introduces increased importance to the selection of a dredging
system for the Thompson Island Pool. The original program
defers final selection of either a hydraulic or clamshell/
pump-out system until the competitive bidding for the dredging.
At that time the cost-performance characteristics of the
systems could be based upon conclusive cost data.
With a reduced scope program significantly less funds
will be available for the second season dredging of the lower
pools. If a clamshell/pumpout system is not used at Thompson
Island pool remaining funds may not allow construction and
amortization of special equipment that would be required for
the lower pools. The impacts of this situation should be
evaluated in detail in the upcoming pre-design studies for
Thompson Island Poo"1 Results of these studies may indicate
that hydraulic dredging of Thompson Island is not feasible in
the total rescoped program.
: B-15
-------
Although not evaluated in this report, the reduced hot
spot dredging will tend to reduce contaminant mass emission
rates resulting from project operations during the life of the
program.
Thompson Island Pool - The Thompson Island pool is a
clear choice for inclusion in the rescoped program. Cost
analysis indicates that the dredging, transport and treatment
cost per pound of PCB removed in this pool is $62. This is
the lowest unit cost for any of the pools. In addition,
probing and sampling programs have been more detailed in this
pool than in any other, permitting confidence in the PCB
location and concentration data used. Studies have also shown
that the river bed materials in this pool are subject to
scour, and that there is no significant conflict with wetlands
in the hot spots in this pool. Finally, this pool is located
closest to the containment site, facilitating transport.
Lower Pools - Based on a range of costs per cubic yard
for dredging, transport and treatment, between 160,000 and
265,000 cu yds of material could be dredged in the lower pools
within the budget constraints of the rescoped project.
Using the MPI estimates of contaminated volumes and PCB
masses listed in Table 2, and applying the criteria discussed
previously to each of the lower pools, results in the prior-
itization of hot spot dredging by pool as shown in Table 3.
Incorporating the range of lower pool dredging - 160,000
to 265,000 cy yds - with the volumes listed in Table 3 yields
the following. Using the lower range value of 160,000 cu yds
only hot spots 29-34 in the Lock 5 Pool will be dredged.
Using the higher range value of 265,000 cu yds, both hot spots
29-34 in the Lock 5 Pool and approximately 80 percent of hot
spot 37 in the Lock 3 Pool will be dredged. Table 4 details
the hot spots to be dredged under the rescoped program.
B-16
-------
TABLE 3
PRIORITIZATION OF HOT SPOT DREDGING BY POOL
Priority
Number
1
2
3
4
5
Location
Lock 5 Pool
Lock 3 Pool
Lock 2 Pool
Lock 4 Pool
(4)
Lock 6 Poolv '
Hot Spots
to be Dredged
29-34<1>
37
(2)
38-39U;
36
21-24 and^ '
26-27
Volume to
be Removed
(cu yds)
155,350
137,800
67,000
134,150
55,500
PCB
Mass
(lb)
22,530
11,680
5,020
5,000
2,460
Cost per
lb PCB
Dredged,
Transported
and
Treated
(1983 dollars)
$100-170
$180-290
$200-330
$400-670
$340-560(4)
(1) Hot Spots 28 and 35 have been identified as containing significant
wetlands and hence have a lower priority for removal.
\
(2) Hot Spot 40 has been identified as containing a significant wetland
and hence has a lower priority for removal.
(3) Hot Spot 25 has been identified as a significant wetland and hence
has a lower priority for removal.
(4) Lock 6 Pool is non-navigable and therefore inaccessible to dredging
without special provisions incurring considerable expense. Cost per
lb PCB removed does not reflect these additional costs.
Note: Prioritization was done using the MPI estimates of contaminated
volumes and PCB masses listed in Table 2.
B-17
-------
TABLE 4
RESCOPED PROGRAM
Hot Spot Dredging
High Estimate of Unit Cost
Pool
Thompson Island
Lock
Hot Spots
1 thru 20
29 thru 34
Contaminated Material
vol, cu yd PCS Mass, Ib
645,500 105,800
155,350 22,530
800,850
128,330
Hot Spot Dredging
Low Estimate of Unit Cost
Pool
Thompson Island
Lock 5
Lock 3
(1)
(2)
Hot Spots
1 thru 20
29 thru 34
37 partial
Contaminated Material
vol, cu yd PCS Mass, Ib
645,500 105,800
155,350 22,530
109,650 9,310
910,500
137,640
(1) Hot Spots 28 and 35 are identified as containing significant wetlands
and hence have a lower priority for removal.
(2) Partial removal will recover approximately 80 percent of in-place PCB
in Hot Spot 37.
Note: All values based upon MPI estimates as presented in Draft EIS,
N.Y. State Environmental Quality Review, September 1980.
B-18
-------
Under the rescoped dredging program between 37 and 40
percent of the 347,200 pounds of PCB in the hot and cold spot
in the Upper Hudson river bed will be dredged. Under the
original project, 49 percent of the PCB in the river bed was
expected to be dredged. The PCB masses used in calculating
these percentages are the total masses of PCB associated with
the volumes of material expected to be dredged. These percent-
ages therefore do not reflect quantities of PCB missed in the
dredging process, lost to the water column or returned to the
river in treatment plant effluent. Earlier studies have shown
that the losses in these three areas total in the range of 6
to 9 percent. A comparison of the percentage removal of PCB
under the original and rescoped project is shown in Table 5.
Estimated costs for the rescoped program are presented in
Table 6.
This dredging program is based upon removal of hot spots
as complete units with partial removal when estimated project
funds will not allow for complete removal of the last hot spot
dredged. Those hot spots which contain wetland areas have been
avoided.
An alternative removal program would be to make partial
removal of a hot spot area on the border of a wetland and
leave the wetland area undisturbed. The additional probing and
sampling program proposed in 1981 will provide the detailed
data necessary for developing such a removal program. Some
existing additional data not used in the present analysis will
also assist in such an effort.
An alternative program involving partial removal of hot
spots containing wetlands may give a slightly higher removal
of PCB than the rescoped program described herein. The dif-
ferences, however, will not significantly change the environ-
mental and cost impacts of alternative removal programs.
B-19
-------
TABLE 5
PCB QUANTITIES TO BE CONTAINED UNDER THE ORIGINAL AND RESCOPED PROJECT
Location
Upper Hudson River Bed
Hot Spots
Cold Areas
Subtotal
Remnant Deposits (Banks)
Subtotal
DOT Spoil Areas'3^
Dumps(6)
Mass of PCB
71,455-96,980
736,130-745,000
Original Project
Mass of PCB
to be
Removed from
Location (lb)
169,900
177,300
347,200
46,770
393,970
169,900
0
169,900
41,200(2)
211,100
% Removal
of PCB f
Location
rom
35,300-35,700
(4)
328,100-337,000
(5)
100%
0
49
Totals
1,201,555-1,235,950 574,500-583,800
88%
54%
37-49%
44-45%
47-48%
Rescoped Project
Mass of PCB
to be
Removed from
Location (lb)
128,330-137,640
0
128,330-137,640
0
128,330-137,640
% Removal
of PCB from
Location
76-81%
0%
37-40%
0
33-35%
35, 300-35, 700V '
0<6>
37-49%
0%
163,630-173,340
(1) Removal estimates do not account for quantity of PCB missed in the dredging process, to the water column
during dredging, or returned to the river in treatment plant effluent.
(2) Remnant deposit areas 3 and 5 - complete removal. Partial removal options not included.
(3) Materials which are not planned for movement under rescoped project, but for which containment site
capacity exists.
(4) Three DOT spoil areas - Spoil Area 13, Site 212 and Site 204 Annex.
(5) Three dumps - Old Fort Edward, Fort Miller and Caputo. See (6).
(6) All dumps to be stabilized in place under the DEC - General Electric agreement of
Septemter 23, 1980.
B-20
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TABLE 6
ESTIMATED COSTS FOR RESCOPED PROGRAM
(All costs in Thousand Dollars)
Phase
Site Construction
and Acquisition
1981
(3)
1982
(4)
1983
(4)
(1)
$3905
Intermediate Cover
Cover Costs
Site Modifications
After Closure^ '
Remnant Deposit Areas 3 & 5
Top Dressing and Fencing 200
Thompson Island
Pool Dredging
Lower Pool Hot Spots
Dredging
Material Rehandling
Sub-Total $4105
Contingencies 371
Engineering Design 978
Probing and
Sampling 500
Monitoring 600
Field Engineering &
Construction
Administration 384
Legal & Administrative 290
Totals By Year $7228
Total For Project
$ 100
$1071
429
6534
221
$6855
2057
800
100
400
880
305
$11,397
3060
199
$4759
1428
50
400
1078
320
$8035
Total by Phase
$ 3905
100
1071
429
200
6534
3060
420
$15,719
3856
1828
600
1400
2342
915
$26,660
$26,660
Notes:
(1) Includes site work costs for all phases, except site modifications
after closure and cover costs.
(2) Includes south dike channel, additional swale drops, and razing and
regrading the roughing & storage pond, surge pond and the treatment
plant basins.
(3) Escalated 13.2 percent from third quarter 1980 to mid-1981.
(4) Escalated 24 percent from 1979 to 1980, and 10 percent/year from 1980.
B-21
-------
Containment Site
The original containment area had an approximate capacity
of 2,260,000 cu yds. This provided for all 40 hot spots,
remnant deposit areas 3 and 5, and the three selected DOT
spoil areas. Under the rescoped project, the required con-
tainment volume was reduced due to the deletion of remnant
deposit relocation and containment and the reduction in hot
spot dredging. In addition, the fluff factor"- applied to
the dredged hot spot material in the Thompson Island pool was
reduced due to a probing and sampling program done in this
pool, autumn, 1980, by Gahagan, Bryant & Associates. For
these reasons, the required containment capacity under the
rescoped project is approximately 1,100,000 cu yds. This
capacity is sufficient to accommodate hot spots 1 thru 20 in
the Thompson Island pool, hot spots 29 thru 34 in the Lock 5
pool and hot spot 37 in the Lock 3 pool, all with the required
fluff factors.
The actual capacity of the rescoped containment area was
determined by reducing the size of the original containment
area to a point where further reductions resulted in only
minimal savings. The capacity of the rescoped containment
area is approximately 1,400,000 cu yds. This additional
volume of 300,000 cu yds gives the project the flexibility to
accommodate any of the following:
o Containment of DOT Spoil Areas - Spoil Area 13,
Site 212 and Site 204 Annex
o Partial Remnant Deposit Removal and Containment -
Partial Area 3 and Complete Area 5.
o Complete remnant deposit removal - Areas 3 and 5.
o Containment of any additionally dredged hot spot
materials if costs are less than expected or more
monies become available.
[1] Fluff factor is defined as the ratio of volume in
containment to volume in situ.
B-22 .
-------
o Provision for the occurrence of unexpectedly high
fluff factors.
The funding for any removal and transport of either the
DOT spoil areas and the Remnant Deposits is not included under
the rescoped project.
On the basis of the rescoped containment areas reduced
volume the following modifications were made to the contain-
ment site:
o Reduction of leachate collection system
o Revised and reduced storm water drainage system
o Reduction of appurtenances
These reductions in the containment site result in a cost
savings of $1,065,000.
The proposed two season dredging plan will still be
incorporated in the rescoped project. The contaminated mate-
rial dredged during the first season will be covered between
the two seasons.
The Thompson Island dredged material will be placed in
one half of the containment area, and capped with a permanent
clay cover.
The final clay cap cover has also been reduced by the
rescoped containment area.
Other areas of possible savings which will be investi-
gated in the redesign are:
o balancing cut and fill operations
o lowering containment dike heights
o using filter fabric and additional crushed stone in
lieu of paving storm water drainage channels
o leaving the roughing and storage, surge pond, and
treatment pond dikes in place after completion of
dredging program
B-23
-------
OTHER PROGRAM ELEMENTS
Probing and Sampling Program
Prior to dredging any of the pools below Thompson Island,
there will be a comprehensive program of probing for bottom
characteristics and sampling for PCB contamination in these
down pools. This additional data is essential to more pre-
cisely delineate hot spots and will be used to finalize the
lower pool dredging strategy.
Sediment samples will also be taken at remnant deposit
areas 3 and 5 to verify depth of contamination. In addition,
additional sampling will be done in the Hudson River above and
adjacent to these deposits to determine their PCB contribution
to the water column.
The lower pools dredging program and any actions taken at
the remnant deposits will reflect the results of these studies.
Monitoring Program
A brief description of the proposed program for monitoring
the effectiveness of the dredging program follows. A more
detailed description is under preparation by DEC and will be
available by mid-March. The program will include two overlap-
ping categories of monitoring, environmental and operations.
Environmental monitoring will involve atmospheric, aquatic
and terrestrial sampling before, during and after the comple-
tion of dredging activities. Samples will be taken at least
daily during dredging and more intensively during early phases
of the project to provide supplemental operations control
data. Dredged material will be regularly sampled to assure
that the dredging operation is recovering contaminated material.
Environmental monitoring after the completion of dredging
will record the more immediate effects of the PCB dredging
program on PCB levels in the air and water; and, later, any
residues on land, foliage and in animal tissues.
B-24
-------
The following studies will be included under the environ-
mental monitoring program:
o Sediment Transport Monitoring
o Hudson River Fish Flesh PCB Analysis
o Sediment PCB Desorption Study
o Biological (Macroinvertebrate) PCB Uptake Study
o Foliar Contamination by PCB in Washington County
Forage Crops
o Air-Plant PCB Relationships
o Agricultural Inplace Studies.
o Site 10, ground water monitoring.
Operations control includes both monitoring and dredge
control. The dredge phase losses, bucket losses, losses to
the water column and air, and the loss of PCB in the treatment
plant effluent will all be monitored. The purpose of the
monitoring is not simply to record the effectiveness of the
related processes, but to provide "real time" data that can
increase and maintain the best attainable dredging efficiency.
RESCOPED PROGRAM SCHEDULE
In this section the assumed schedule for the rescoped
project is presented:
o Containment Site Construction (Summer 1981)
o Sampling and Probing Program (Summer 1981) for the
Lower Pools
o Dredging Thompson Island Pool (Summer 1982)
o Additional Sampling and Probing Program for the
Lower Pools, if Required (Summer 1982)
o Partial Closure of Containment Area (1982)
o Dredging of some of the Lower Pools (Summer 1983)
o Final Site closure and Site Modifications after
Closure (1983)
o Monitoring before, during and after all phases.
B-25
-------
REFERENCES
Phase 1 Engineering Report, Dredging of PCB Contaminated
Hot Spots, Upper Hudson River, NYy Malcolm Pirnie, Inc.,
(December 1978).
PCB in Sediments and Water, and Their Transport, New York
State Department of Environmental Conservation,
(March 1980).
Telephone conversation between Dr. E.H. Buckley, Boyce
Thompson Institute, and James Catterton, MPI,
(January 30, 1981).
Comments on PCB Hot Spot Dredging Program, Upper Hudson
River, New York, Rescoping Report, USEPA, (February
1981).
-------
APPENDIX C
Review of the Sediment Transport Model
and the PCS Ecosystem Model
Appendix C contains a review by WAPORA, Inc. of the Sediment Transport Model
(Lawler, Matusky and Skelly Engineers, 1978; 1979) and the PCB Ecosystem Model
(Hydroscience, Inc., 1978; 1979).
-------
Appendix C
1. REVIEW OF LMS SEDIMENT AND TRANSPORT MODEL
A sediment and PCB transport model was developed by Lawler, Matusky &
Skelly Engineers to assess the impact of the "No Action" alternative and subse-
quently to evaluate two "Action" alternative schemes. The results of these
modeling studies are presented in two reports by Lawler, Matusky & Skelly Engi-
neers (LMS 1978, 1979).
This review is designed to put the PCB transport in the Hudson River into
perspective with the "No Action" alternative. The review is concentrated in
two aspects: overall methodology and technical results.
The overall methodology adopted by Lawler, Matusky & Skelly Engineers is
not clearly understood. This selection of the HEC-6 model as the basis of the
sediment transport model seems adequate but without a thorough discussion of the
other models available. A model review and selection process is missing from the
report. Further, the linkage of the HEC-6 model and the water quality problem
(in this case, PCB transport in the Hudson River) is lacking. This may be due
to the lack of discussion of the goals of this modeling study. In addition, how
the temporal and spatial scales of the selected model and of the water quality
parameters to be addressed match is not presented.
The biggest drawback of the LMS approach of using the HEC-6 model is that
the HEC-6 model is designed for alluvial stream beds while the PCBs in the
Hudson River are associated with fine organic materials. The sedimentation
characteristics between alluvial channels and fine-particle beds are quite
different. After all, the PCBs in the hot spots are primarily associated with
the fine organic particles (Hetling et al. 1978). It should be pointed out that
the LMS sediment and PCB transport model have been calibrated but not verified
because of lack of adequate data.
The most difficulty encountered in reviewing the LMS report is Chapter 4,
Model Calibration. There are significant amounts of data analysis presented in
this chapter such that it is difficult to differentiate which is data analysis
C-l
-------
and which is model calibration. Further, in most cases, the data are so scat-
tered and not substantial. The comparison of model calculation with observation
seems more like a pure model calculation. Usually, at the end of model cali-
bration, a summary of key model parameters is presented. This particular list is
missing which makes the review extremely difficult. At best, only the model
segmentation list is found in Appendix D without any other parameters (such as
hydrographic characteristics, at the least) used in model calibration.
It is understood that the HEC-6 model calibration was based on a relatively
short time period of field survey data. In order to conduct long-term projec-
tions of PCB movement, a proper transition from short-term computation and
long-term projection is required to accommodate such a change in temporal scales.
The report stops short of its transition effort at statistical analyses of
the Hudson River and tributary flows. The other key features of the sediment
and PBC transport such as upstream boundary conditions are not specified.
Subsequently, a summary of the model projection scenarios is not presented,
although model projection runs were conducted for constant source, diminishing
source, and flow control conditions.
Based on the above discussion, the LMS modeling is not considered a state-
of-the-art approach. Additional data are required to further refine the calcu-
lations. Therefore, the results from the LMS study should not be taken as the
definitive predictions of PCB transport in the Hudson River. Instead, the
results can be considered as the "best" estimate and trends of PCB loadings from
the upper Hudson River to the estuary. Effort should be examined to construct a
rational and credible analysis of the transport and ultimate fate of PCBs in the
movable bed sediment PCBs, the PCBs in the sediments, and the PCBs in the water
column, in order to estimate accurate transport loads in the Hudson River.
Nevertheless, the LMS studies provide as preliminary assessment of average
annual PCB loads to the estuary in terms of No-Action, Remnant Deposits Mitiga-
tion, and Hot Spot Dredging alternatives. The results of the LMS studies have
been modified by WAPORA in order to reflect the effects of volatilization and
routine navigational dredging in the upper Hudson River.
C-2
-------
2. REVIEW OF HYDROSCIENCE PCS ECOSYSTEM MODEL
Hydroscience (1978, 1979) developed a food web model to simulate PCBs
in the Hudson estuary ecosystem. The model was used to estimate the possible
effects of remedial acton, to reduce PCB sources in the upper Hudson River, on
the Hudson River ecosystem. In addition, the model was used to determine the
fate of PCBs in the ecosystem of the Hudson estuary. These tasks were accom-
plished by analyzing the existing PCB data on the water column, various portions
of the food chain and the striped bass, within the modeling framework. Projec-
tions of expected reductions were made and compared to the existing action level
of 5 ug/g and the proposed action level of 2 ug/g in fish.
The analysis framework upon which the food web model was developed is
at the state-of-the-art stage. With the full utilization of available data
during the study period, the model provides the best estimate and range of charge
in PCB levels in the Hudson estuary ecosystem which will result if the PCB
water column concentrations are reduced.
The Hydroscience model was developed based on the fundamental mass balance
principle in a deterministic fashion. The model has a solid scientific basis
as well as sound engineering practicality. Of course, each model has its limi-
tations. The Hydroscience model is no exception. The reports clearly describe
the model assumptions and the associated limitations. As a result, it should
be noted that the results from this modeling analysis are not meant to recommend
any remedial actions. Instead, the modeling report indicates the necessity
of a systematic data collection process program to detail the PCB concentrations
in the sediments, water column, and biomass of the estuary is needed so that
an additional basis will be available for estimates of the fate of PCBs.
Some key conclusions from the modeling analysis help to put the remedial
action into perspective in terms of PCB levels in fish. Projections indicate
that if a concentration of 0.01 ug/1 was obtained in the estuary, as a re-
sult of remedial measures, then the striped bass body burden of juvenile and
4-year-old fish would decline to 4-8 ug/g depending on the assumed excretion
rate. Older fish under a "worst case" would not decline below 15 ug/g. The
C-3
-------
response time to reach these levels is estimated to be 2-4 years from the time
reduction in water concentration is accomplished. Significant reductions in
the PCB levels in the striped bass would accompany the assumed concentration
of 0.01 ug/1 in the estuary water column. However, the results indicate the
virtual impossibility of reducing striped bass body burdens over the near term
to the level of 2 ug/g (the proposed action limit) due to the potential for
high bioaccumulation in the striped bass and the ubiquitous presence of PBCs.
Based upon the above conclusions, it is seen that the benefit of remedial actions
(such as dredging) would not be immediately realized in fish.
3. CONCLUSIONS OF THE REVIEWS
Based on the LMS modeling results, dredging is expected to offer reduction
of PCB transport into the Hudson estuary. However, the effect of dredging
would not be immediately realized in fish in the estuary. In fact, the response
time in fish upon extensive reduction of upstream PCB sources may vary from a
year to perhaps less than a decade. However, significant evaporative losses,
estuary sediment burial, and slow diffusion rates in sediment may shorten this
response time. Compared to the No Action alternative which is estimated to take
longer than at least a decade to flush out PCBs from fish, dredging offers a
substantial reduction of response time, if not immediately.
The conclusions on fish recovery are based on the water column PCB concen-
trations in the estuary which, in turn, depend on the PCB transport load from
the upper Hudson River into the estuary. The conclusions, therefore, hinge
on the predictions of PCB transport. It was concluded earlier that the PCB
transport model still needs refinement with additional calibration. It is
recommended, therefore, that effort should be expended to construct a rational
and credible analysis of the transport and ultimate fate of the PCBs in the
estuarine water column (dissolved and particulate), the movable bed sediment
PCBs, and the PCBs in the sediments, in order to estimate water column response
times in the estuary under different control strategies.
C-4
-------
Continued work is necessary to further refine the food chain model and
striped bass model as the data become available, in order to provide a better
understanding of PCB transfer in the ecosystem, and to improve the ability
to forecast PCB responses under different environmental controls.
It is recommended that remedial action be taken to remove the PCBs in
the upper Hudson River. Until then, flow control should be implemented to
mitigate the storm effects which would resuspend the PCBs and further disperse
the PCBs into the estuary. In the meantime, field monitoring should continue
to expand the data base and to provide understanding of the problem in the
Hudson River and estuary.
C-5
-------
APPENDIX D
Cost Estimates for In-River Containment of
Hot Spots and Covering of Remnant Deposits
MPI (written communication) March 16, 1981. The cost of rock diking around
hotspots 28 and 35; and sheetpiling. Memorandum from J.A. Bedard,
Engineer, Malcolm Pirnie, Inc., White Plains, New York to Howard Schwartz,
Project manager, WAPORA, Inc., New York, New York.
Mulligan, J.B. (written communication) March 6, 1981. Cost estimates for clay
cover at remnant deposit sites 3 and 5. Correspondence from J.B. Mulligan,
Engineer, Malcolm Pirnie, Inc., White Plains, New York to R.F. Thomas,
Project manager, Malcolm Pirnie, Inc., White Plains, New York.
MPI (written communication) April 22, 1981. Cost comparison for dredging and
alternatives to dredging; cost for incineration. Memorandum from J.A.
Bedard, Engineer, Malcolm Pirnie, Inc., White Plains, New York to Howard
Schwartz, Project manager, WAPORA, Inc., New York, New York.
-------
MALCOLM PIRNIE, INC.
Consulting Environmental Engineers
}0 2 Corporate Park Drive, White Plains. N.Y. 10602
914/694-2100
D 11 Computer Drive West, Albany, N.Y. 12205
518/458-7884
D 5002 Canal Road. Cuyahoga Heights, Ohio 44125
216/641-5830
D 6161 Busch Blvd., Columbus, Ohio 43229
614/888-4953
D S. 3515 Abbott Road. Buffalo. N.Y. 14219
716/828-1300
D 301 Hiden Blvd., Newport News, Va. 23606
804/599-5511
D 100 Eisenhower Drive. Paramus, N.J. 07652
201/845-0400
D 1617 John F. Kennedy Blvd., Philadelphia, Pa. 19103
215/564-0172
D 8757 Georgia Ave., Silver Spring, Md. 20910
301/587-5355
D 500 South 22 St. (Suite 212), Birmingham, Ala. 35233
205/322-0513
D 2500 Hollywood Blvd.. Hollywood. Fla. 33020
305/923-9131
To:
Jit EaM 43 "* -St.
Date:.
Re: _
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Attention:
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GENTLEMEN: Sxfe&S
We are sending you 81 Enclosed D Under separate cover via El Mail D Messenger, the following items:
D shop drawings
D specifications
D prints
D sketches
D data sheets
D brochures
D
D
Our action relative to items submitted for approval has been noted on the drawings.
COPIES
,
1
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PREPARED BY
M?r
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REFERENCE NO.
THESE ARE TRANSMITTED AS CHECKED BELC
BT As requested D Approve
D For your use D Approve
D For review & comment D Revise a
D For your information D Not App
Remarks-
DESCRIPTION
Ufar fro* eriH«KM -TO JGfoZctf *«**»/. W/L* e*sis
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-------
MALCOLM PIRNIE, INC.
Inter-Otfice Correspondence
R.F. Thomas Date; V.6/81.
. J.B.,. Mulligan
Cost Estimated for Clay Cover at
Subject:
Remnant. Deposit Sites 3 and 5
As requested by Judy Bedard, we have prepared a cost estimate
for covering the above referenced remnant deposit sites to reduce
PCB volatilization and the percolation of surface water into
the sites. The estimate is based upon the following criteria:
o The minimum depth of clay cover practical is 18-inches;
o To prevent the cover from drying out and cracking,
a 12-inch thick layer of material suitable for
establishing turf will be placed over the clay trover;
o The areas will be seeded to wild grasses;
o The face of the stone fill bank and channel protection
can not be effectively sealed as it must drain with
changes in river depth;
o Two existing drains under a railraod spur at Area 5
presently discharge onto the site and should be
extended across the site to the river using good
drain pipe or a paved ditch;
o The access road at Area 3 is still useable without
acquiring a new easement.
o Surface waters flowing onto both sites from the
highlands away from the river does not have to be
intercepted and carried around the sites but can be
carried over the sites as sheet flow.
JBM;mhn
D-2
-------
BY Of. DATE..
CHXO. BW DATE
SUBJECT
fo
or
or
MALCOLM PIRNIE, INC.
2 CORPORATE PARK DRIVE
WHITE PLAINS, N.Y. 10602
SHEETNO ............. OF
JOB NO
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or
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-------
MALCOLM PIRNIE, INC
CONSULTING ENVIRONMENTAL ENGINEERS
April 17, 1981
Mr. James G. DeZolt, Project Manager
Hudson River PCB Reclamation Project
N.Y. State Dept. of Environmental
Conservation
50 Wolf Road
Albany, New York 12233
Dear Mr. DeZolt:
This will summarize cost estimates prepared by Malcolm
Pirnie, Inc. for several alternatives considered in the
Hudson River, PCB Reclamation Project.
1. Rock Dikes or Sheetpiling (Hot Spot 35)
a) Hot spot dredging of 27,250 cu. yd. containing
2,090 Ib. PCB has a 1980 dollar cost of $440,000
for typical second season dredging. This includes,
dredging, transport and return flow treatment.
b) Several dike (or sheetpiling) configurations were
evaluated. Costs (not including annual mainten-
ance, access or engineering and administrative
costs) ranged from $370,000 to $510,000 (1980
dollars). Further evaluation will be required to
determine the most feasible sections. See attached
Bedard memo to WAPORA, 3/16/81 for details.
2. Top dressing and fencing of remnant deposit areas 3 and
5 is estimated at $200,000 plus contingencies, engi-
neering and administrative costs (page 20, Scoping
Report, March 1981).
2 CORPORATE PARK DHIVE WHITE PLAINS, N.Y. 10602 914-694-2100
ALBANY. N.Y. CUYAHOOA NTS, OHO PAAAUUS. HJ.
BUFFALO. N.Y. rI NEWPORT NEWS. VA (~~| FMLADELMA, PA
| | KM-SM-MII | |
ri«-«2*-llO> I I KM-SM-MII I I 1U-6M4171
COLUMSUS, OHIO M.VER 8PMNO. W>
14-MS-496* J01-M7-4M4
Cttto: MAUVWENO, N.Y. TCLCX I37M4
D-4
-------
MALCOLM PIRNIE, INC.
3. Costs for clay cover and fencing at remnant areas
3 and 5 are given on page 3 of the Response to USEPA
Comments transmitted to Mr. Manning by Mr. Thomas's
letter of March 26, 1981. The value for clay cover
for area 3 given on page 3 should be corrected to
$400,000. The cost for clay cover for remnant deposit
area 5 is $180,000.
4. A preliminary estimate of cost for a rock blanket
to cover in-place hot spots is $160,000/acre of
river bed covered. This system is quite prelimi-
nary and will require extensive further analysis
to prove feasibility. (See attached memo TDV-4/13/81.)
5. The cost of incinerating two million cu. yds. of
river bed material using current multiple hearth
technology is on the order of $200,000,000.
Very truly yours,
MALCOLM P/RNIE, INC.
Richard F. Thomas, P.E.
Project Manager
RFTrhkh
cc: Robin Rohn
D-5
-------
/$ DATE^MO. " MALCOLM PIRNIE, INC. SHEET NO..../..... OF..<£
BY"tHr 2 CORPORATE PARK DRIVE
CHKD. BY DATE WHITE PLAINS. N.Y. 10602 JOB NO.
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SUBJECT .......................... _
MALCOLM PIRNIE, INC.
2 CORPORATE PARK DRIVE
WHITE PLAINS. N.Y. 10602
SHEET NO
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BY !..£f. DATE
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MALCOLM PIRNIE, INC.
2CORPORATE PARK DRIVE
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SHEET NO ! OF .?..
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BY....1...^ DATE.
CHKD.BY DATE.
SUBJECT
MALCOLM PIRNIE, INC.
2 CORPORATE PARK DRIVE
WHITE PLAINS. NY. 10602
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D-9
-------
MALCOLM PIRNIE, INC
Inter-Office Correspondence
To:
From: ..
Subject:
RFThomas
FCristea /f-£~
PCB - Hudson River - Dredged Material Incineration Costs
Date:....?/2.2/?!...
266-22-1400
Based on the following data:
a. Dredged material 30% water & 70% sand/silt
by weight
b. Solids contain 10% volatiles having heating
value of 10,000 BTU/LB
c. Total mass desity of 92.8 Ibs/cubic foot
d. Total volume of dredged material is 2 x 10
cubic yards
e. Total time for a continuous operation to
be five years.
Calculations
a. Total weight of dredged material ....
2 x 106 yds3 x 27 ft3 x 92.8 Ibs = 5.01 x 109 Ibs
c.
d.
e.
f.
b. Total weight of dry material ....
2 x 106 yd3 x 27 ft3 x 92.8 Ibs x .7 = 3.51 x 109 Ibs
Loading rate ....
5.01 x 1Q9 Ibs = 114,000 Ibs/hr (Total mass)
8760 hrs x 5 yrs
yrs
3.51 x 1Q9 = 80,000 Ibs/hr (dry material)
43800
Number of Incinerators required ....
114,000 Ibs -s- 23,000 Ibs = 5 units
hrs hrs
Note: Use five incinerators plus one stand-by unit
Total = six incinerators
Capital Investment costs for incinerators ....
at $15,000,000 per unit, installed
Total investment costs = $90,000,000
(Includes escalation through 1984)
Fuel required ....
Fuel required for combustion at 180Q°F = 898 GPM
Fuel required for combustion at 2200°F = 1533 GPH
Total fuel required ....
D-10
-------
At 1800°F = 898 gal x 8760 hr x 5 yrs = 39 x 106 gallons
hrs yr
At 2200°F = 1533 x 8760 x 5 = 67 x 106 gallons
Projected average cost of fuel oil during 5 year period =
$1.75/gal
39 x 106 x $1.75 = $68,250,000
gal
67 x 106 x $1.75 = $117,250,000
gal
3. The installation of heat recovery boilers or combustion
air preheaters will reduce the amount of fuel oil required
significantly.
A computer analysis was made, using a preheater to
raise combustion air to 800°F, that calculated a f\
oil consumption of 214 gallons/hr
214 gal x 8760 hr x 5 yrs = 9.37 x 106 gallons
hr yr
9.37 x 106 x $1.75 = $16,397,500
gal (fuel savings over 5 year)
Estimated additional capital investment costs for.
preheaters is $15,000,000 installed and adjusted for
escalation through 1984.
4. Summary .(without air preheaters) ....
Combustion Temperature
180QQF 2200°F
Fuel required (gal) 39 x 106 67 x 106
Fuel costs $1.75/gal $68,250,000 $117,250,000
Capital Costs:
Incinerators $90,000,000 $ 90,000,000
Material Handling Equip.
costs $ 9,000,000 $ 9,000,000
Estimated Labor Costs $ 5,000,000 $ 5,000,000
$172,250,000 $221,250,000
FG/rf
cc: RFBonner
SCSchwarz
JJTansey
D-ll
-------
APPENDIX E
Water Quality Data
-------
Table E-l
Classifications and Standards for Fresh Surface Waters
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'
___ -
/
N4lufil Htlural Naliutl
Source: ' MPI (1978a)
NOTIil
II A itilnliiwm of llv« ntln«1lon« ! lavillftii.
II Clandii^ |a bo mot dullno oil p«|luilo 01 dlolnlocllon.
II Adillilond oloniJ>iil> >ppllcU la Iho iiliuvo clittUlcollonc Tiublilliyna Inciooio Ihol will ouoo oiibtliniUI vUlhlo eanlroii |a fiiluiil condlilond Colocllon* fiotnnvivmodo oouicoo Ihol
Mill ! d»lilnwnl«l lo !!» p«cllloij bo«l utiuo bl wolBfftl SuvpuniUd. coll»rfUI M oilior oolldl*Nono Itom any MM«IO dltclitffa* vwtilch will Ckuto d«pd«tllon to Iho toll MMQO ol Wftoii Oil of«J
flciMltno i4i«t*nc«**Nii fotlilno ollfIbutiulo lu o MB«I« dUvlipiu* nor vlilblo oil film nM QliibuUo of g)*»««I lotto onj o*lur|ivuduclfi0 bbiloncoo, lo>lc *vool«« ond Jvloloilobo otjb«lnncoB-Nono
|!ID| will bo ln|i«louo lo llth III* M wliltb Vtlll oJvoiobly ll»cl Ilio flovlrf. felui Ol tdix, Ihtloul, o> kiiptlc Ibo woUlt lot Iho (DoCllltd botl uooao of wollll tl»lln«l dl llw <*»!<» uiit>lo l>f untullnblo Iw ony alaltllUil uto.
4| Wlih «»l»ionco la CMIoln Ionic tob«l«n<-.«» ill^cllng fldi III*. Itx. oil»bllihn«ii| ol ony olngU nixnallvtl olt»dMo tio moiiy wtloi.
vlilth borouto ul iiou« Iiiill«ili4 copicllr-ond cumpoililon will «o>i>il'* ii'tcltl nutty to ditoirtilno o>lo cdnconlioilont of liinlc OLbiitncoi. llowovor. nnol of Iho »»< In IMi tlolo will hovo on ll.tlliillr al SO iiillllunnii iwf lllo< M obovo. WlilAU coiuldailna Inciootil *y bo cuntla«lo4
» t«lo Iffaftin coliconlttlluno tut Collolti oubtloncoo la canvlv wllh tlio obovo tlonjttd Im lido lypo of wtlor* Wolol ot lowol olkollillty nuial bo tpoclllcolly Co»tld«lo4 olfko tho loilc ollocl
of n^tl Mollwlaitlt will bo (iioolly ltici*«»«iJ. AnfiajnU o* A<»io«ood
o* Cu;-<|n(-llul (10*1*1 Ilitn 0.1 Killllyitnio p« Ilior *>pi 2n| C*dmlun-fJtl viotioi ihtnO.l (nlllluitmt p« lli*r anpitotoii tt Cj.
-------
Constituents (nit/1)
Dlaaolved Oxygen
C.0.1).'
Total Suspended
Sol Ids
Phosphates (as P)
Nitrates (aa N)
Heavy Metals (|ig/l)
Arsenic
Copper
Hercury
Lead
Cadniuia
Chromiiua (tot.)
Cyanide
Zinc
PCB3 (Mg/1)
* For waters with
** Criterion exprei
Table E-2
Water Quality Constituents, Upper Hudson River
Fort Edward
(H.P. 192.2)
) Ha*. Hln. Mean
14
25
8
)'
2
20
2
18
(1
(1
' (1
(1
.4 7.4
.0 4.0
t
1
.22 .01
.70 .16
.0 0.0
.0 0.0
.8 <0.5
.0 0.0
reading)
reading)
reading)
reading)
10. B
15.0
4
.13
.36
0.5
8.5
<0.7
8.0
1.0
0.0
10.0
60.0
Thomson Schuylervl lie
(H.F. 181.4)
Max. Hln. Mean Max. Hln. Mean
14.6 10.0 13.0
19.0 14.0 16.3
13 2 7.5
.09 .06 .07
.44 .32 .36
10.0 0.0 2.4
20.0 0.0 8.0
7.0 <0.5 <1.8
15.0 2.0 6.4
2.2 0.0 0.5
Sllllwaler
(M.P. 165.7)
Max. Hln. Mean
13.6 6.4
22.0 5.0
29 2
.22 .02
.64 .10
10.0 0.0
20.0 0.0
3.0 <0.5
62.0 3.0
2.4 0.0
10.2
13.2
7
.07
.39
3.7
6.3
<0.75
14.6
0.6
Waterford
(M.P. 154.0)
Max. Hln. Mean
16
24
78
1
1
40
0
300
10
20
100
1
.4
.0
.14
.10
.0
.0
.8
.0
.0
.0
.0
.4
7.1
12.0
1
.01
.18
0.0
0.0
0.4
4.0
0.0
0.0
10.0
0.0
10.6
17.5
13
.07
.51
0.4
12.1
<0.5
66.8
1.6
8.6
33.6
0.3
NYS ... USEPA
Standards Recommended
(Class A Criteria for,..
through 0) Aquatic Life13'
5.0 sig/1
(3.0 for D)
Cannot be
deleterious
to best use
200 pg/1*
300 (Jg/1*
100 ug/1*
300 |ig/l*
Not impair
S.Os.g/1
.
10t reduction
of nor*, comp.
pt.
0.1 sig/1 total P
90 sig/1 for
warnwaler fish
.
**
.05 |ig/l
**
0.4 |ig/l for
aena. orgs. in
soft water
100 |ig/l
5.0 |ig/l
**
.001 pg/1
fish, or
best use
greater than 80 ag/l alkalinity. In less buffered vater such as the Hudson River, these Uailts would be lowered.
aed aa a percent of the 96-hour LC50 (that concentration lethal to 50 percent of individuals, using a sensitive resident species).
Notes:
1. NYSDEC Water Quality Surveillance, Water Quality Statistical Snnmary Report 10-1-75 to 9-30-76. (Thomson results froai HYSDEC Water Quality
Surveillance, Raw Data Listing 10/74 to 4/75).
2, IISGS Water Resources Division, Albany, NY, 1971 to 1976. Wnter Quality D«ta. Hudson River System.
3. (ISCS Water Resources Division, Albany, NV. Water Quality Data Water Year October 1976 to September 1977.
4. Slate of New York, Official Compilationi Codes. Rules and Regulations. Article 2, Part 701, "Classifications and Standards of Purity."
5. USEHA, 1976. Quality Criteria for Water (prr-piibUcotloa copy).
Source: MPI, 1978a
E-2
-------
Table E-3
PERFORMANCE OF REMOVAL SYSTEMS,
PCB HISSED OR LOST FOR COMPLETE HOT SPOT DREDGING PROGRAM
HYDRAULIC DREDGING OF THOMPSON ISLAND POOL HOT SPOTS
CLAMSHELL DREDGING OF LOWER POOL HOT SPOTS
Total PCB in Hot Spots
PCB Kissed by Dredge
2% with Hydraulic Dredging
Hydraulic
Dredging
(Thompson Island Pool)
PCB Mass
-------
TABLE E-4
SUMMARY, BED MATERIAL HEAVY METAL CONCENTRATIONS
Concentration in pg/g
LOCATION
Fort Edward'1'-East Channel
(RM 194.2-194.3)
West Channel
(RM 194.3-194.4)
Buoy 214 (RM 192.4)
[2]
Thompson Island Pool
(RM 188.4)
[2]
As
ND
ND
2.1
1.9
Cd
0.78
1.0
0.95
0.46
0.76
1.1
27
Cr
9.1
12.9
7.7
8.4
23.7
255
450
Cu
21.2
18.9
16.1
19.0
29.9
35
53
Pb
18.2
26.7
19.2
18.5
77.5
150
375
. He
0.17
0.11
0.10
0.06
0.10
NM
NM
Ni
7.4 '
8.7
10.2
6.9
9.9
16.5
24
AB
NM
NM
NM
NM
Zn
50.6
53.2
52.8
43.3
57.8
150
245
Moses Kill (RM 189.1) IJJ
50 Barrel Sample
40 Barrel Sample
Northumberland (RM 183. 5) ^
Buoy 212
(RM 192. 3) ^
4
4
1.2
NM
16
35
4.4
6.0
560
825
42
27
100
150
3.2
25
440
840
180
77
0.1
1
NM
NM
40
41
NM
NM
26
125
NM
NM
360
680
180
88
Representative Bed Material Concen-
trations, Thompson Island Pool [5]
30
500
100
500
0.5
30
80
500
ND = None Detected, NM = Not Measured
[1] Malcolm Pirnie, Inc., Environmental Assessment-Maintenance Dredging Champlain Canal, Fort Edward
Terminal Channel, p. 111-21, (1977)
[2] Tofflemire, T.J., DEC, Preliminary Report on Sediment Characteristics and Water Column Interactions
Relative to Dredging the Upper Hudson River, (1976)
[3] General Electric Corp., Corporate Research and Development, Laboratory Data Sheet (September 9, 1977).
[4] Tofflemire, T.J., DEC, "Buoy 212 Dredging-Update and Conclusions," Memorandum to Mr. Mt. Pleasant,
(January 1977)
[5] Based on a subjective analysis of the existing data for Thompson Island Pool as presented above
E-4
-------
Table E-5
PROJECTED INCREASES IN AMHIENT HEAVY METAL CONCENTRATIONS FROM DUKDCEHEAD
LOSSES ONLY; HYDRAULIC VS. CLAMSHELL UHEDUES
All values Hg/i except concentration in bed materials, ng/g
Hydraulic Dredge _ _ Clamshell Dredge
Estimated
Representative Initial
Concentration Increase
in Bed
Materials
3
30
500
100
500
0.5
30
80
500
1
Above
Ambient
0.1
0.8
. 11.4
2.2
11.4
0.0
0.8
1.8
11.4
Settling
Estimated Estimated
Final Initial
Increase
Above
Increase
Estimated
Final
Increase
Above - Settling. Above
Ambient Factor Ambient
0.2
1.0
17.2
3.4
17.2
0.0
1.0
2.8 -
17.2
0.5
0.5
0.5
0-5
0.5
0.5
. 0.5
0.5
0.5
0.1
0.5
8.6
1.7
8.6
0.0
0.5
1.4
8.6
Ambient
background
levels-range
and average
Estimated
Cumulative
Ambient
liange
lly.lr. Clmsl.
0.0 - 1.0 0.1- 0.1-
(0.4) 1.1 1.1
0.0 - 10.0 0.4- 0.5-
(1.6) 10.4 10.5
0.0 - 20.0 5.7- 8.6-
(8.6) 25.7 28.6
0.0 - 40.0 1.1- 1.7-
(12.1) 41.1 41.7
4.0 - 300.0 9.7- 12.6-
(66.8) 305.7 308.6
0.4 - 0.8 0.4- 0.4-
(0.5) 0.8 0.8
Not
measured
Not -
measured
10.0 - 100.0 15.7- 18.6-
(33.6) 105.7 108.6
NYSDEC
Certification
Standards
50
10
50
200
30
2
2500
300
1. Cased on a range of bed material values sampled by NYSDEC, General Electric Co., and Malcolm Pirnie, Inc. (see Table 1V-1).
2. Based on in-situ metal levels presented uhove, 2 and 4 percent loss rates for the hydraulic and clamshell dredges, respectively, and
complete dilution of the plume at 3000 cfa.
3. Derived from 2 jar tests performed on Northumberland bed materials without flocculation or filtration of supernatant (Tofflcmire, T.J.,
DEC, 1'rellmlnary Report on Sediment Characteristics and Water Column Interactions Relative to DrcUgiiiR the Upper Hudson River for 1'CB
Removai, 1976.) Sec Appendix F.
4. Measured at Wutcrford. USGS Water Resources Division, Albany, N.Y. Water Quality Data, Hudson River.
E-5
-------
Table E-6
CIIAKCF.S IN AMD1ENT WATER QUALITY AS A RESULT OF COMBINED ESTIMATES OF
UKTUKN FLOW LOSSES AND DREQGEIIEAD I.OSSF.S (ALL UNITS pg/1)
Hydraulic Dfcilge_
Clamshell Drcdgn
Estimated Estimated
Estimated increase Ea Lima ted increase
Increase above above * increose above above
Concentration, ambient from, oiubicat from Total Concentration .ambient from , ambient from Total
In return flow return flow dredgchcad Incrcaie in return flow return flow dredgehead increase
100
500
100
500
2,000
300
20 .
25,000 '
3,000
2.0 (0.1)
10
2.0
10
40
6
0.4
500
60
0.2
0.1
0.4
5.7
1.1
5.7
0.0
0.4
5.7
2.2 (0.3)
9.9
2.4
15.4
40.3
11.5
0.4
490
64.4
100
500
100
500
2,000 .
300
20
25,000
3,000
0.1 (0.0)
0.5
0.1
0.5
2
0.3
0.02
25
3
0.4
0.1
0.5
. 8.6
1.7
8.6
0.0
0.5
$.6
0.5 (0.
0.6
0.6
9.1
3.8
8.9
0.02
26.3
11.7
Ambient
Background ' NYSDEC
Range, Certification.
Vaterford Standards
4) 0.0- 1.42
0.0- l.O3
0.0- 10. O3
0.0- 20. O3
0.0- 40. O3
4. 0-300. O3
0.4- O.B3
Not measured
10. 0-100. O3
0.5
50
10
50
200
30
2
25,000
300
Measurement
1'CB
. Arsenic
Cadmium
Clironium
Copper
Lead
Mercury
Nickel
Zinc
References; . ;...' .
1. Based on NYSDEC certification of NYSDOT 10 year maintenance dredging program for Champlain Barge Canal and Hudson River.
2. USCS, Water Resources Division. Hudson River at Watcrford, N.Y, Route 4 Bridge, Water Year October 1976 to September 1977,
3. USGS, Water Resources Division. Water Quality Surveillance Hrlvork, Trace Metal Analysis. Station 11-003 at Waterford. -April 1975 to July 1976.
4. Without carbon adsorption treatment of return flow. Carbon adsorption estimates for FOB in parenthesis.
S-6
-------
TABLE E-7
NATIONAL INTERIM PRIMARY DRINKING WATER REGULATIONS
Subpart B-Maximum Contaminant Levels
Section 141.11 Maximum contaminant levels for inorganic Chemicals.
(a) The maximum contaminant level for nitrate is applicable to both
community water systems and non-community water systems. The levels for the
other inorganix chemicals apply only to community water systems. Compliance
with maximum contaminant levels for inorganic chemicals is calculated pursuant to
{141.23.
(b) The following are the maximum contaminant levels for inorganic chemicals
other than fluoride:
Level, milligrams
Contaminant per liter
Arsenic 0.05
Barium 1
Cadmium 0.010
Chromium 0,05
Lead 0.05
Mercury 0.002
Nitrate (as N) 10.
Selenium 0.01
Silver 0.05
(c) When the annual average of the maximum daily air temperatures for
the location in which the community water system is situated is the following,
the maximum contaminant levels for fluoride are:
Temperature Level, milligrams
Degrees per liter
Fahrenheit Degrees Celsius
53.7 and below 12.0 and below 2.4
53.8 to 58.3 12.1 to 14.6 2.2
58.4 to 63.8 14.7 to 17.6 2.0
63.9 to 70.6 17.7 to 21.4 1.8
70.7 to 79.2 21.5 to 26.2 1.6
79.3 to 90.5 26.3 to 32.5 1.4
Section 141.12 Maximum contaminant levels for organic chemicals.
The following are the maximum contaminant levels for organix chemicals.
They apply only to community water systems. Compliance with maximum contaminant
levels for organix chemicals is calculated pursuant to { 141.24.
E-7
-------
Table E-7 (Continued)
Level, milligrams
per liter
(a) Chlorinated hydrocarbons:
Endrin (1, 2, 3, 4, 10, 10-hexachloro-6,7-epoxy-l,4, 0.0002
4a 5,6,7,8, 8a-octahydro-l, 4-endo, endo-5, 8-dimethano
naphthalene).
Lindane (1, 2, 3, 4, 5, 6-hexachlorcyclohexane,
gamma isomer). 0.004
Methoxychlor (1, 1, 1-Trichloroethane). 2, 2-bis 0.1
(p-methoxyphenyl).
Toxaphene (CH SI -Technical chlorinated 0.005
camphene, 67-69 percent chlorine).
(b) Chlorophenoxy:
2, 4 - D, (2, 4-Dichlorophenoxyacetic acid). 0.1
2, 4, 5-TP Silvex (2, 4, 5-Trichlorophenoxypropionic acid). 0.01
Source: U.S. EPA, 1976
E-8
-------
TABLE E-8
NATIONAL INTERIM PRIMARY DRINKING WATER REGULATIONS
{143.3 Secondary Maximum Contaminant Levels.
The Secondary Maximum Contaminant Levels for public water systems are as
follows:
Contaminant Level
Chloride 250 mg/1
Color 15 Color Units
Copper 1 mg/1
Corrosivity Non-Corrosive
Foaming Agents 0.5 mg/1
Iron 0.3 mg/1
Manganese 0.05 mg/1
Odor 3 Threshold Odor Number
pH 6.5-8.5
Sulfate 250 mg/1
Total Dissolved Solids (TDS).... 500 mg/1
These levels repreeent reasonable goals for drinking water quality. The
States may establish higher or lower levels which may be appropriate dependent
upon local conditions such as unavailability of alternate source water or other
compelling factors, provided that public health and welfare are not adversely
affected.
Source: U.S. EPA, 1979 E-9
-------
APPENDIX F
The Hudson River Fish Fauna
Smith, C. Lavett. 1977. The Hudson River fish fauna. In: McKeon, Warren H.
and Gerald J. Lauer (eds.) Hudson River ecology. Proceedings of a
symposium. Hudson River Environmental Society Paper No. 32. 12 pp.
-------
THE HUDSON RIVER FISH FAUNA
C. Lavett Smith
The American Museum of Natural History, New York
Because of its morphometry and geographical location,
the Hudson River drainage is inhabited by extraordin-
arily rich fish fauna. About 120 fish species have
been recorded in the literature as occurring in the
Hudson River system and recent collecting has pushed
the rtotal -to more -than 130. In spite of the changes
brought about by human uses and abuses of the river,
there are more different kinds of fishes in the Hudson
now than there were when Henry Hudson arrived in 1609.
There have been a number of successful introductions,
but there are no convincingly documented examples of any
species becoming extinct, although some have not been
reported for a long time and the ranges of others have
been severely restricted.
-------
INTRODUCTION
Like other large rivers, the Hudson has been badly ne-
g^ected and our knowledge of its fishes is far from
complete. Large rivers are singularly difficult to
sample because depth and current prohibit some types of
gear and rough bottom restricts the use of others.
Furthermore, there has been a lack of interest JLn the.
fishing resources of the Hudson for political and eco-
nomic reasons so that little effort has been directed
to the scientific study of its fishes.
The Hudson River fish fauna is a young one. -The entire
drainage was covered by glaciers during the Wisconsin
glacial interval, hence the fauna can be no older than
10/000 years. It has, however, been pointed out that
sections of what is now the Hudson Canyon would have
been uncovered by Pleistocene sea-level"lowering and
may have served as a refugium from which some fishes
could have repopulated the present-day basin as soon as
the glacial front began to retreat (Cole, 1967). Gla-
cial drainage patterns also provided access to the Hud-
son basin from the Gulf of Mexico drainage and this,
more than any other single factor, accounts for the
richness of the Hudson River fish fauna.
HUDSON RIVER GEOGRAPHY AND FISH HABITATS
The upper Hudson, from its source streams in the Adiron
dacks to about the Glen, is a fast-flowing cool, oligo-
trophic stream. --'The granitic rocks are poor in calcium ' .
and relatively insoluable so that minerals are limited.
This region lies within the boundaries of the Adiron-
dack Park and is well forested so that runoff is natur-
ally controlled. -
Between the Glen and Troy, the River flows more slowly
and the underlying rocks provide more nutrients. Be-
tween Warrensburg and Troy, a series of natural water-
falls has been augmented and harnessed for hydro and
hydroelectric power, which has created a series of slow
water environments. Major tributaries, including the
Schroon, the Sacandaga, the Batten Kill, the Hoosic and
the Kohawk, provide still more diverse fish habitat.
Here too, the Hudson is joined by two major canals, the
Champlain-Hudson Canal (opened in 1819) that connects
with the St. Lawrence River and the New York Barge Canal,
the present-day version of the Erie Canal which first
F-l
-------
connected the Hudson with the upper Great Lakes in 1825
(Hubbs and Lagler, 1947:6).
From the Troy lock to the Verrazano Narro\ s, the Hudson
River is a long, narrow tidal estuary. Except for the
Cornwall to Verplanck section where it passes through
the Hudson Highlands, it proceeds southwards in almost a
straight line. All of the estuary is tidal, but the
salt wedge extends upstream only to the vicinity of New-
burgh, its exacc. limit varying according to the amount
of freshwater coming downstream.
In spite of its straightness and austere appearance on
the charts, the lower Hudson presents a wide spectrum of
fish habitats. Islands, tributary streams, shallow flats
deep channels and bays that have been partially walled-
off by railroad beds, provide rich and varied cover for
fishes; and their-food-organisms."" Much of the shoreline
is protected by stone rip-rap that provides excellent she
ter for small fishes.
Although it would appear that the Hudson River is_divided
into well-defined fish habitats, the fishes themselves do
not recognize such sharp distinctions. While it is gen-
erally true that the small creeks of the Adirondacks are
dominated by brook trout and blacknose dace, and the lowe.
Hudson contains such marine species as anchovies and blue-
fish, there are no really pronounced faunal breaks. Many
species have a wide range in the River - the yellow perch
white suckers and golden shiners, for example, are taken
in small Adirondack streams and also in the main River at
Haverstraw. Most species have preferred habitats in whicJ
they reach their greatest abundance and marginal habitats
where they exist as minor components of the community.
Thus, a complete study of their distribution must also in-
clude information on relative and absolute abundance. Un-
fortunately, it is frequently the unusual or stray indivi-
ual that finds its way into museum collections, and for
this reason a plot of recorded occurrences often does not
give a true picture of the species range.
FISH DISTRIBUTION PATTERNS
MARINE AND EURYHALINE FISHES
Numerous marine fishes enter the lower Hudson and travel
upstream varying distances depending on their ability to
tolerate freshwater. Some are present throughout much of
F-2
-------
the year; others come in only at certain seasons. Still
others are strays or wanderers" and:are recorded only
sporadically. In theory, almost any species from the
North Atlantic, or even the West Indies, might at some-
time enter the lower, reaches of" the Hudson, and. new ..
records will appear .as.long as we.continue :to study the
River. .. - . ... .- ;
A- Marine.and Euryhaline Species" Commonly" Taken in'the
Hudson ... . . .,.,"... . ... . " .
"'lie jack crevalle, Caranx hippos, is an example of a
marine fish,that is frequently taken.in the River.during
later summer and early fall. -.Like the bluefish,(Pomato-
mus saltatrix), the weakfish (Cynoscion regalis)"and .the
silver perch (Bairdiella.chrysura), it appears, .to enter
the River in.numbers only when young. Most" of the"jack
crevalle are less than 6" long and .presumably are", less
than one..year old. - .. . ...._..-; . ... ..':'"--.. '".-" - .
j . .r . .-, .-,-, _..
Other marine and brackish water fishes"common"in the
lower Hudson are:; . . ... . . .,-.. ...
Brevoortia tyrannus
Anchoa mitchilli ..
Strongylura marina
Fundulus heteroclitus
Menidia menidia.. ..... .
Menidia beryllina. ;
Syngnathus fuscus
Apeltes quadracus .
Morone americana
Pomatomus saltatrix .-
Lutjanus griseus. ...
Leiostomus xanthurus
Mugil cephalus
Paralichthys dentatus
PseuQOpleuronectes. ...
americanus,- . .. .
Trinectes jnaculatus
Atlantic", menhaden'. ''..
Bay anchovy, '".._. ^". ' '.
Atlantic ."needlefish'
Mummichog... ^'J. ,
Atlantic silverside
Tidewater silverside
Northern 'pipefish
Fourspine" stickleback
White, perch ""
Bluefish: ;^. ... '
snapper.
Spot .',' . ".' '..
Striped, mullet. -"-.. .
Summer, flounder (.fluke)
Winter flounder
Hogchok'er: -'. '..
. ~ ....«. .
Of these, Apeltes quadracus, .Morone americanus-. and: Tri-
nectes maculatus are able to' tolerate freshwater for ex-
tended periods and range well upstream.,, Lutjanus griseu-
is a West Indian species, once recorded from near Tarry-
town (Boyle,..1968: 33)
F-3
-------
B. In contrast to these regular inhabitants, some other
marine species are rare or sporadic in the lower Hudson
and have only been taken on one or a few occasions:
Carch a r h i nus_ obscurus
Kaia laevis
G^-ilus nor~.ua
Flerluccius bilinearis
Membra s r.artir.ica
H* T--^I-| 3TTT-. :i c £j*-or-^-
.*. «* » V_> «» u»*.. »_ _ w CZ _ . ,^. L* w
Pur. m ni us C'-jnai-iu
Gasterosteus aculeatus
Myoxocepa^^us QCI.O-
qecerr.sdnosus
Rachvcentiron canadum
Lut janus criseus
Kicrooojon undulatus
Peorilus triancanthus
Dusky shark
Barndoor skate
Atlantic cod
Silver hake
Striped killifish
Rough silverside
Lined seahorse
Ninespine stickleback
Threespine stickleback
Longhorn sculpin
Cobia
Gray snapper
Atlantic croaker
Butterfish
C. Some of the best known Hudson River fishes are dia-
dromous forms that spend part of their life cycle in
fre_shwater and part in salt. The American eel, Anguil-
la. rostrata, is"a catadromous species that must return
to the sea to spawn. Juvenile and adult eels are ex-
treir.ely abundant in the lower Hudson and even up into
the Mohawk River, where there was formerly a consider-
able fishery for eels.
Three- herrings, -the .American shad (Alosa sapidissima) ,_
the blueback (Alosa aestivalis) and the alewife -(Alosa"-'-
pseudoharengus}, are well known for their spring spawning
runs, as is the striped bass (Morone saxatilis) . During
the late fall and winter months, the tomcod (Microgadus
tomcod) moves into the River to spawn.
Other anadromous fishes are:
Petromyzon marinus
Acioenser brevirestrum
Aciuenser cxyrnynchus
Osir.erus mordax
Sea lamprey
Shortnose sturgeon
Atlantic sturgeon
Rainbow smelt
Although there are a few early records of Atlantic sal-
mon, Salmo salar, entering the River, it is doubtful that
the Hudson was ever a salmon stream (Boyle, 1969:39-41).
F-4
-------
FRESHWATER FISHES
The freshwater fishes of the Hudson River pose some
interesting distribution problems. Introductions
both deliberate and accidental - occurred early in
our history, in many cases long before there was any
attempt to determine the original ranges of the spe-
cies in question.
A. Lake-Dwelling Species
The lake trout (Salvelinus namaycush Walbaum) , the
round whitefish (Prosopium cylindraceum Pallas), and
the lake whitefish (Coregonus artedii Lesueur) are
apparently native species, having invaded the region
through glacial outlets and lakes at the end of the
Pleistocene. Their habitat requirements restrict them
to lakes rather than streams.
B. Wide-Ranging Stream and River Species
The following list includes species that-are generally
distributed on the Atlantic coast and occur in stream
drainages on each side of the Hudson. Their presence
is, therefore, expected and, in general, they offer no
clues as to the corridor by which they invaded the Hud-
son River drainage.
Lampetra lamottei
Dorosoma cepedianum
Salvelinus fontinalis
Espx niger
Esox americanus
americanus
Erimyzon oblongus
Catostornus commersoni
Hypenteliuro nigricans
Kotemigonus crysoleucas
Exoglossura maxillingua
Semotilus corporalis
Semotilus margarita .
Semotilus atromaculatus
Rhinichthys cataractae
Rhinichthys atratulus
Phoxinus eos
Pimephales notatus
Notroois hudsonius
American brook
Gizzard shad
Brook trout
Chain pickerel
lamprey
Redfin pickerel
Creek chubsucker
White sucker
Northern hog sucker
Golden shiner
Cutlips minnow
Fallfish
Pearl dace
Creekchub
Longnose dace
Blacknose dace
Northern redbelly dace
Bluntnose minnow
Spottail shiner
F-5
-------
Notropis cornutas Common shiner
Kc-ropis bifrenatus _ Bridle shiner"-
Hybocnathus nuchalis -. -- - -
recius Silvery minnow
Ictalurus nebulosus Brown bullhead
Ictalurus natalis Yellow bullhead
Perccpsis oT.iscornaycus Trout-perch
Fundulus~diaphanus Banded killifish
Culaea inconstans Brook stickleback
Enneacanthus obesus Banded sunfish
Lepomis auritus Redbreast sunfish
Lepomis gibbosus Pumpkinseed
Perca flavescens Yellow perch
Stizostecion vitreurn
vitreum Walleye
Percina caprodes Logperch
Etheostoma olmstedi Tessellated darter :
Cottus cognatus Shiny sculpin
The gizzard shad, Dorosoma cepedianum, is of particular
interest because it has only recently been taken in the
River (Dew, in press). Whether it arrived via the Cham-
plain-Hudson Canal, the barge canal or along the coast
is not obvious. " - . .
C. Northern Species Reaching Their Southern Limits In
Or Near the Hudson
Some of these species occur only in headwater tributaries
and-were presumably able to become established through .
glacial outlets as the ice receded. Probably they are
habitat (temperature?) limited. The range of Hybognathus
hankinsoni Hubbs, for example, extends from the Missouri
drainage of Colorado, Wyoming and Montana across Nebraska
and The Dakotas, Wisconsin, Iowa, Northern Illinois,
Michigan and Southern Ontario to the Adirondack region of
New York (Bailey, 1954). Others have even broader ranges.
The longnose sucker, Catostomu's 'cat'os'tomus' Forster, occurs
in eastern Siberia as well as most of Canada and the Nor-
thern United States.
Esox lucius Northern pike
Catostomus catostomus Longnose sucker
Moxostoma macrolepidotum Shorthead redhorse
Couesius plumbeus Lake chub
Phoxinus neoaaeus Finescale dace
Pimephales promelas Fathead minnow
F-6
-------
Hybognathus hankinsoni Brassy minnow
Notropis heterolepis Blacknose shiner
Nbtropis heterodon Blackchin shiner
D. Species That Reach Their Northeastern Limit in the
Hudson
There are species of the Atlantic coastal plain that
have not extended their range north or east of the Hud-
SCT? Valley. Possibly they are temperature limited,
but other explanations cannot be ruled out at this time.
Umbra .pygmaea Eastern mudminnow
Notropis chalybaeus Ironcolor shiner
Ictalurus catus White catfish
Noturus ihsignis Margined madtora
Noturus gyrinus Tadpole madtora
Acantharchus pornotis Mud sunfish
Enneacanthus gloriosus -Bluespotted sunfish
E. Two other species, the rosyface shiner (Notropis^
rubellus) and the spotfin shiner (Notropis spilopterus)
have wide ranges in the Mississippi and Great Lakes
drainage and on the Atlantic coast when N. spilopterus
occurs in the Susquehanna, Delaware and Hudson basins,
and N. rubellus is found south to the James River.-
They have not, however, extended their ranges to the
east.
F. Introduced Species
Species that are not native to Northeastern North Amer-
ica are clearly introduced, but there are some species
that occur in nearby drainages and may or may not have
been introduced. I believe that the following species
were intentionally introduced into the Hudson River
system.
Salrno salar Atlantic salmon
Salmo trutta Brown trout
Salmo gairdneri Rainbow trout
Carassius auratus Goldfish
Cyprinus carpio Carp
Micropterus dolomieui Smallmouth bass
Micropterus salmoides Largemouth bass
Pornoxis annular is White crappie
Pomoxis nigromaculatus Black crappie
F-7
-------
Air.blopl-i.tes rupestris Rock bass
Lepomis iriacrochirus 'Bluegill
«
The restricted occurrence of the green sunfish, Lepomis
cvanellus, in the New Croton Reservoir, and the warmouth,
aulosus, in the Sawkill near Anandale, strongly
"
suggests .that, they were accidentally "introduced (Greeley,"
1937:102-103).
Finally, there are several species whose presence in the
Hudson drainage may have resulteu- from their moving
through canals. Most canals, however, follow ancient"
stream connections and glacial outlets, and for this rea-
son we cannot always be certain that the species was ab-
sent before the canal was built. Thus, Gibbs (1963; 525)
interpreted the presence of Notropis analostanus in the
Mohawk-Hudson as "evidence "in favor of a formerly wider
distribution in New York, for the species probably en-
tered that river system when it was the outlet for the
waters of glacial Lake Lundy or Lake Iroquois." In con-
trast, Snelson (1968:796) states, "There are two alter-
nate explanations for the widespread occurrence of No-
tropis a therinoides, in the Mohawk-Hudso_n system. Trans-
fer could have been via the Mohawk outlet which shunted
water from glacial Lake Vanuxern down the Mohawk-Hudson
Valley. ... Just as likely, however, is the hypothesis.
that Notropis atherinoides more recently entered the Hud-_
son drainage via the~Erie Barge Canal system which was
opened as a continuous waterway connecting the Finger
Lakes - -Lake .Ontario "drainage with the Mohawk Hudson -
drainage in 1825."
Western species that probably gained access through the
Erie Canal are:
Umbra limi Central mudminnow
Notropis atherinoides Emerald shiner
Clinostiomus elonaatus Redside dace
Labidesthes sicculus Brook silverside
Etheostoma blennioides Greenside darter
Species that could have entered through the Erie Canal
or through the Champlain-Hudson Canal, since they occur
in the St. Laurence River.
Noturus f lavus Stonecat
Korone chrysops White bass
Etheostoma flabellare Fantail darter
F-8
-------
The hornyhead chub, Nocomis bi outtatus, reaches its
eastern limit an the Mohawk system, where Hubbs and
Lagler (1947) considered it to be native.
Three species are known only from western tributaries
of the lower Hudson with a few records from the River
itself. They are Notroois amoenus, Notropi s analos-
tanu.? and Per c in 3 peltataT Tnese ir.ay have entered the
Hudson drainage £>y stream capture where the Wallkill
reversed its flow from the Delaware drainage to the
H-jcscn drainage. One must also consider the possibility
that they gained access through the Delaware-Hudson
Can^l. .
SII«»Mftp
U.T irtrv
In addition to its well-known corrjnercial and sport
fishes, the Hudson River basin contains a wide variety
of smaller fishes that serve to indicate the dispersal
routes through which the fishes .repopulated the River "
after the retreat of the last Wisconsin glacier.
More than 100 species live in the Mohawk-Hudson system
and twenty-two additional species have been reported so
infrequently that they can be considered visitors, al-
though our present knowledge is quite sketchy and this
judgement may be modified in the near future.
The origin and distribution of Hudson-Mohawk fishes can
be summarized as follows:
I Species
MARINE AND BRACKISH WATER SPECIES ' "~
A. Common (Residents at least part of
the year) 20
B. Rare (Transients) 22
C. Diadromous 10
FRESHWATER SPECIES
A. Lake-Dwellinq Soecies 4
B. Wide-Ranging Species 34
C. Northern Species 9
D. Atlantic Drainage (reaching northern
limit in the Hudson) ..... 7
E. Western (Mississippi Drainage) 2~~
F. Introduced Species
1. deliberately introduced 11
2. accidentally introduced 2
3. canal introduction
F-9
-------
a. Erie Canal 5
b. Champlain-Hudson or Erie 3
c. Erie Canal or native 1
d. Wallkill or Delaware-Hudson Canal 3
133
While introductions have increased the faunal list,
other human influences (such as impoundments and eutro-
phication due to domestic sewage and other fertilizers)
have tended to favor the most tolerant species at the
expense of others. The concept of diversity should in-
clude equitable distribution of numbers. Although there
are more kinds of fish in the River today, the over-
whelming preponderance of a few species (carp, white
perch, striped bass, sunfish) means that the fishes are
actually less diverse than they were in primeval times.
Lower diversity is generally a sign of a deteriorating -
environment, at least in terms of aesthetics.
LITERATURE CITED
BAILEY, R.M. 1954. Distribution of the American cyp-
rinid fish Hybognathus hankinsoni with comments on
its original description. Copeia (4):289-290.
BOYLE, R.H. 1968. Notes on fishes of the lower Hudson
River. Underwater Naturalist 5(2):32-33, 40.
BOYLE, R.H. 1969. The Hudson River. A natural and un-
natural history. W.W. Norton £. Co. , New York,
304 pp.
COLE, C.F. 1967. A study of the eastern johnny darter,
Etheostoma olmstedi Storer (Teleostei, Percidae).
Cnesapeake Sci. 6:25-51.
GIBBS, R.H. 1963. Cyprinid fishes of the subgenus
Cyprinilla of Notropis. The Notropis whipplei -
analostanus - chloristius complex. Cooeia (3):511-
528.
GREELEY, J.R. 1937. Fishes of the area with an annota-
ted list. IN: A Biological Survey of the Lower"
Hudson Watershed. Suppl. Ann. Rept. New York State
Conservation Department, 26:45-103.
SNELSON, F.J. 1968. Systematics of the Cyprinid fish
Notroois amoenus, with comments on the subgenus
Notropis.Copeia (4):776-802.
F-10
-------
TABLE I: Taxonomic Distribution of the Hudson River
Fish Fauna (includes some unpublished records)
Fsrr.ily Number of Species
Petromyzontidae 2
Carcharinidae 1
P.ajidae 1
Acipenseridae 2
Anguillidae 1
Clupeidae 5
Engraulidae 1
Salmonidae 8
Osmeridae 1
Esocidae 3
Umbridae 2
Catostoir.idae 5
Cyprinidae 28
Ictaluridae 6
Percopsidae 1
Gadidae 4
Ophidiidae 1
Belonidae . l
Cyprinocsontidae 3
Atherinidae 4
Syngnathidae 2
Gasterosteidae 4
Percichthyidae 3
Lutjanidae 1
Centrarchidae 13
Percidae 7
Po-.atonidae 1
Rachycentridae 1
Carangidae 3
Sciaenidae 4
Labridae 1
Kugilidae = 1
Stroinatidae 1
Cottidae 2
Eothidae 3
Pleuronectidae 1
Soleidae 1
Tetraodontidae 1
F-ll
-------
APPENDIX G
Hudson River Fish PCB Analysis
1979 and 1980 Samples
New York State Department of Environmental Conservation, unpublished data,
Hudson River PCB analysis - 1979 and 1980 samples. Albany, New York.
-------
'HUDSON RIVER PCB ANALYSES - 1980 SAMPLES
I'oije 1
LOCATION
Cat ski 11
Poufjlikeepsle
ilcwburgh
Pccksklll
Indian Point
Tuppan Zee
.I'.rldge
NUMBER
SPI-XIES ANALYZED
Redbreast Sunfish
7/30/80
American shad (4/29)
Roe
American shad (5/15)
Largcmouth bass (5/23)
Yollow perch (5/23)
Chain pickerel (5/23)
Walleye (5/23)
American shfld (5/9)
Roe
Pumpkinseed
(Age 1+) 9/6/80
American shad (5/7)
Roe
American eel (10/28) t
American shad (5/8)
Roe
20V ;
30
.. 7 - :
1
20 '
10
: 2 ' .
1 .
29
' 7 . '
75 '
31
7
6
. 30
7 ' :
AVERAGE . 'LENGTH AVERAGE
NO. OF .. LENGTH ' RANGE WEIGHT
. ANALYSES : ' (mm). .'.. (mm) . (g)
. 20 . : "'.'
30 . i ; '
S-,.-: . . ; i;.
:. ':'i: '.- . v:-:
20 ':
' 10-
-. 2 .' -:': ;
V
i ':"..'.; .''
29 i '..;.
V 3 ': . '
' 25 '" ;. -'
1 ' .
31
3
6 ' : ...
30
3 ' ' ' t
179 ,
516
527
.443
321
229
386 ''."
519
517
529
529 :
357 ,
516 '.'
525
.-;' i'160-194
459-56S
y 506-545
;.|" -
. '. 260-410
, 169-325
I ! 345-428
463-559
449-547
, V
i, . ' .
, 476-582
. 501-561
306-452
445-580
: 490-546
135
1652
1769
790
632
164
382
1710
1762
1786
27
1916
1937
110
1806
1984
WEIGHT
RANGE
(8)
100-200
1100-2120
1550-1920
--
230-1365
70-395
230-535 '
1160-2360
1560-1970
--
1500-2490
1700-2490
70-180
1450-2480
1690-2300
AVERAGE
LIPID
(7.)
1.7
11.3
1.4
3.9
0.4
0.2
0.2
1.7
12.1
0.9
4.9
12.3
2.1
4.8
12.7
0.9
LIPID
RANGE
a)
<0. 1-12.0
5.4-17.4
1.3-1.6
--
0.1-2.6
0.1-0.5
0.1-0.2
3.3-19.2
0.8-1.0
3.2-6.2
5.1-16.8
1.2-2.4
0.9-11.3
7.0-18.6
0.7-1.9
AVERAGE
pen
2.64
1.79
< 0.42
0.96
<1.08
<0.98
5.61
1.42
<0.32
4.63
1.27
<0.30
9.07
1.55 '
<0.30
pen RANCI-:
ll>l.1ll>
<0.30- 25.11
< 0.52-4. 04
--
<: 0.30-3. 10
< 0.30-4.92
< 0.43-1.53
0.6J-3.87
<0.32-<0.'J5
2.20- 7.23
<0. 54-3. 40
<0.30-<0.30
2.14-23.05
< 0.52-3. 04
<0.30-<0.30
G-l
-------
HUDSON RIVER PCB ANALYSES - 1980 SAMPLES
NUMBER
LOCATION
above Feeder Dam
SciLlwater
Albany/Troy
NO. OF
AVERAGE
LENGTH
SPECIES .ANALYZED . ANALYSES , (mm)
Pumpkinseed
(Age 1+) 9/9/80
Hrovm Bullhead
6/23/80
Yellow Perch
6/23/80
Largemouth Dass
6/23/80
Pumpkinseed
(Age 1+) 9/10/80
Goldfish 6/23/80
Brown Bullhead
7/29/80
Furapkinseed
(Age 1+) 9/2/80
American shad
Roe (5/28)
Blueback herring (5/28)
White perch (5/28)
Walleye (5/28)
Northern pike (5/Z8)
72
,-
30
7
26
75
30
21 .
75 :.'.
A '
1
AO
30
A
2 '
2A '
30
7
26
: 25
30
21
25
A
1
1
30
A
2
\
('.-"
.265
"
, ; . 213
. '- '
267
" ' t
247
233
''-. .
' ' ' """ n
518
572
276
. ". 182:
A7A. .
. .616
LENGTH
RANGE
(ram)
2AO-299
187^261
126-396
. '
220-289
178-335
. : ' «
A50-572
-- .
s 230-312
' 161-236
355-605
"'' 535-696
AVERAGE
WEIGHT
(8)
18
235
134
AOO
19
306
226
26
1528
2390
194
110
1326
1630
WEIGHT
RANGE
. (B)
155-355
90-220
35-990
..
170-A85
110-600
--
790-2390
--
120-280
70-235
A10-26AO
1030-2230
AVERAGE . LIPID
LIPID RANGE
('/.)
3.9
0.9
0.1
0.5
3.2
6,7
l.A
3.9
6.2
1.0
5.6
5.2
1.2
0.3
(7.)
3.3-4.6
0.3-2.5
£0. 1-0.1
0.1-2.6
1.9-4.5
0.6-18.7
0.1-5.6
2. 9-.S. A
2.8-11.7
~
--
1.6-13.2
0.5-2.2
0.1-0.6
AVEIUCE
pen
(ppm)
<0.60
12.34
<0.84
10.16
20.12
72.62
2.09
16.74
1.72
<0.31
1.81
16.71
6.22
2.28
pea iw::r.t:
(ppm)
<0.46- <0.fl7
3.50- 30.11
CO. 33- 2.15
1.67- 66.78
14.80- 29. AS
11. 47-267.61
<0.30- 7.96
12.66- 22.59
<0.a5-3.9'J
"
' -- '
2.60-46.17
2,30-10.11
1.08-3.A7
-------
HUDSON'RIVER pen ANALYSES i960 SAMPLES
LOCATION
SPECIES
, NUMBER
ANALYZED'
NO. 07
ANALYSES
. AVERAGE,
> LENGTH
',. LENGTH " AVERAGE ' WEIGHT AVERAGE LIPtD AVERAGE
'..RA.VGE WEIGHT ' Ri\NCE LIPID RANGE . PCU
.Cram) ' (g) (g) _tt) ('/.) Jp_P5lI_
I'cukskill
Croton. Pt.
(Vcrplanck)
Toppun Zee Bridge Striped bass
4/14/80
5/8/80
Striped bass 27
5/9/80
Striped bass ' 27
5/7/80
Striped bass 23
4/14/80 (confiscated)
Coori'i: Washington Striped bass
Urlclgc 4/30/80
5/13/80
30'
30
30
30
27
27
.30
30
3d
561 .
;';' 520 .':'/;
. ' 468 ? '"*
: -515 ' .'
4515
558 :
510-761
488-903
448-721
! 342-578
.426-682 1*
415-655
!403-758
2070
3443
1643
1242
1553
1563
2032
1500-4605 9.2
.1430-9430 5.9
990-4890 "! 5.4
480-2200
780-3140
720-3370
620-5660
3.2
3.1
3.0
3.8
0.5-18.9 1.99
1.5- 8.9 9.05-
0.8-12.0 11.68
0.4- 7.3
0.4- 9.8
5.59
6.37
0.1- 8.9 5.00
0.8-14.4 4.44
<0.30-ll.f.V
2.47-47.01
2.33-52.12
<0.90-14.28
<0.y'J-41 .(iL)
<0.f.l-19.79
1.B2-12.59
G-3
-------
HUDSON.RIVER PCB ANALYSES - I960 SAMPLES
Pai;o 3
LOCATION
SPECIES
eorge U'aiiliingcon American eel(7/24)
Itriclge
li!i- 40(Hanhattan) American eel (7/24)
crrnzano Bridge American eel (6/18)
:ist R. American eel (6/18)
llritlge)
NUMBER
ANALYZED
19
16
29
NO. OF
ANALYSES
19
16
29
AVERAGE . LENGTH-
" LENGTH '.. f .' RANGE
' (mm) ' f - : (mm)
.' l
476 . / 409-587
486: ;<: 396-600
AVERAGE WEIGHT
WEIGHT RANGE
(B) (g)
244
140-440
374
'421
199-543
236-620
247 120-450
138 20-350
195 40-590
AVERAGE
LIPID
CI.)
11.9
LIPID
RANGE
m
2.7-16.7
AVERAGE
PCB
8.15
9.2 1.5-16.6 5.89
5.5 1.7-16.7 6.76
10.5 . 1.1-25.4 7.13
. PCB RAM:F,
(pi"")
2.43-12.74
-------
HUDSON RIVER PCB ANALYSIS - 1979 COLLECTIONS
Part I
' '. (unless otherwise noted analyses were of individuals on a standard fillet
;'!.' j,. ;.,AVERAGE. ;. .: .. .. ' ... '^AVERAGE AVERAGE
IQCATtiTN
Aliovc Feeder Dam
(Cluns Fulls)
Suillwator
Waterford
Moluiuk R.
1/2 ml. from
Hudson R.
bclou Lock 7
Albany /Troy
Ciicskill
Kingston
Crugcr Island
liso|Hi8 Creek
Uondout Creek
(near mouth)
I'oughkecpsie
SPKCIES
Pumpkinseed
Brown bullhead
Pumpkinsccd
Drown bullhead
Largcmouth bass
Smallmouth bass
Ulueback herring
Pumpkinseed
Brown bullhead
Alewife
Alewife
Pumpkinseed
Carp
AlewiCa
llainbow smelt
Carp .
Alewife
Atlantic tomcod
; NO. OF '
FISH
68 (17)*
' ' J '" '1
20
64 (16)*.
.30
30
4 '.''! '
30 ','
88 (22)*
22
18
13 ' :'
:
23 (23)*
13 .' : .
18 .''/ .
' 25 ' '::.' '
5 .
24
13
; .(. LENGTH '! i
(nun) .
, . i
.-'' : 96' '- "f
''"' ' }',' ' '
308 ': ; '
97 " v
251 .'
317 '.'; i
V : -' '"' ' "'
373' ' ' :
:'276 ' /,:
I.'L! V' " '
' 112. ; -.'
;. 292 ..".
-.;. 27:> Vi,
273 '. .
! ' .
.-: 111." '.'.'
. -621 -.';'
. 290 .'' :
-' '''
134 ; '
566 .-.
287
164 :
LENGTH RANGE V WEIGHT
(nun) . (e.)
'i' ' ''
;: 76-113 '''. \ .-"']: -
"' (' '. -I.'' ':
277-339. "' ';':'. 441
78-121- . s
178-315 " 225
250-405...: .. 494
V *
349-394 '.-.'. .. 900
256-307 .'..:' '.'' 180 '
" .. - -,' ' ' '" «
'''.', '.:'-': '
86-135, '. : --
193-338 .-: 384
245-315 ,. £/ 223
250-290 237
96-130
" I
464-813
270-310 !;
110-170
356-705
255-315
137-222
. i! ' :
' '' ' '
' ' 3417
: .'" 281 .
. . . -.r
s 8
3136 .
268
. 34 .
WEIGHT RANGE LIPID
(G)
.
295-600
50-370
200-960
667-1036
113-255
.
__'
85-653
165-379
' . 180-345
1644-6804 .
200-330
4-20
2551-4252
175-370
15-100 '
(/,)
3.2
0.4
i.9
0.8
0.4
2.4
4.1
1.8
2.2
8/3
7.0
4.3
10.7
5.8
2.3
9.6
8.2
0.6
basis)
LIPID RANGE
C/.)
2.2- 4.0
0.1- 1.7
1.4- 2.4
0.1- 7.5
0.1- 1.4
2.1- 3.0
0.*>- 7.8
0.7- 2.8
0.05-10.6
3.0-13.6
2.4- 15.1
2.4- 6.0
4.4- 18.0
2.1- 14.9
0.9- .6.0
7.6- 14.0
3.8- 12.8
0.3- 0.8
AVERAGE
PCD ;
(npni)
<0.4;4
,
*b.y$-
19.91
8.97
4.60
4.68
2.33
5.89
< 6. 74
4.79
2.28
5.56r
42.63
2.64
4.03
14.73
2.55
<0.67
PCH RAKCK
rpnni>
<0.33-<0.67
%
<0.30- 1.14
15.63-25.43
-------
HUDSON RIVER PCB ANALYSIS .- 1979 COLLECTIONS
{oi-L II
LOCATION
Nuwliurgli
Cornwall-on
Hudson
Foundry Cove
Peukskill
Tomkins Cove
llavucstrau Dny
Tapyian Zee
bridge .
Tuppan Zee
Bridge
SPECIES
Pumpkinsccd
Rainbow smelt
AlewiCe
White Catfish
Blue claw crab
llcpatopancreas
Muscle
Bluefish
Carp
Ulue claw crab
llepatopancreas
Muscle
Atlantic tomcod
Blue claw crab
Intnct-no shell
Hepatopancreas
Muscle
Striped bass
3/29/79
11/20/79
American shad
'' NO. OF
FISH
100 (25)*
16
20
2
5 .
: 5 ' : . .
16
8
7 ... :
7
15.,,' .. .':
' '."'..-
5
5
' 5, "
14
15
15
'AVERAGE
. LESCTII '';
(nun)
119
139
283
: 374
. ' " : .
' . ... ..
177
632
'' ' ' v '
*'
152 ..
'.,. i '
'. .. ..''
' ~~V '
. '': , '
'456 '*-' V
366
511
AVERAGE
LENGTH RANGE
( nun)
93-134
120-180
245-315
355-392
. : ' .
.."' ' / '
i ';'";; >.
121-203 .:
392-753^ ' -
.
: . , '
,.
118-183 ^ . . ..
' ' "_
:
. . -v.
. . : '' '
424-495 1
305-566
485-561
WEIGHT
(B)
9
262
610
.
74
3863
25
1070
601
1728
'WEIGHT RANGE
(K)
5-20
160-380
454-765
57-113
822-4536
10-60
880-1249
341-2043
1195-2540
AVERAGE
LIPID
(%)
4.0
2.3
8.1
3.5
5.3
0.2
1.5
. 8.6
3.2
0.4
0.9
. .<
2.7
4.2
0.2
5.5
4.7
17.7
AVERAGE
LIP ID RANGE
CO
2.1- />.8
0.5- 4.3
2.6-13.3
. 2.1-5.0
3.4- 7.6
0.1- 0.3
0.4- 3.3
3.0-14.0
1.7- 4.6
0.2- 0.7
0.2- 7.8
.
1.6- 4.5
0.9- 7.7
0.2- 0.5
2.7- 9.2
2.3- 9.8
9.5-23.3
pen
(ppni)
2.99
4.51
2.71
12.12
9.64
<0.34
3.15
56.49
4.62
<-O.G9
< 0.37
2.95
6.75
<0.40
5.27
. 8.53
1.37
PCD UA
'npm
1.H5-
1.57-
<0.90-
5.32-
5.00-
<0.30-
< 0.65-
<0.73-
2.70-
<0.30-
C.0.30-
< 1.73-
<0.89-
< 0.30-
2.11-
<0.59-
0.57-
:!C.i-:
)
4.1H
'J . 4 7
5.5(.
lU.'Jl
20.21.
<0./,5
6.61
iiy.o
8.51
<; 2..ty
<0.57
5.55
16.92
<; 0,71
10.71
27.11
2.51
*Number In p.-irenthesio reflects number of composite analyses on a whole body .basis of yearling fish.
G-6
-------
PCD ANALYSIS OF AMERICAN EEL FROM HUDSON RIVER TRIBUTARIES - 1979 COLLECTIONS '
LOCATION
SPECIES
"'' ': ' AVERAGE' , "' . ' 'AVERAGE . AVERAGE
. NO. OF' '-LENGTH ' LENGTH RANGE X.'WEIGHT WEIGHT RANGE ' LIPID LIPID RANGE
.'. . FISH . (mm) ; (mm) ' . (g) (p.) (%) W>
AVERAGE
PCB PCI1 IIASCG
(ppiu'j (ppnO
Catsklll Creek
(So. Cnlro)
Normnnsktll Creek
(lit. 166 & A43)
Moodna Creek
(Vails Gate)
Sowklll Creek
(Ani\andale-on-Hudson)
Raumlll Rtvcr
(Voiikcrs)
American eel
20
: 22
21
20
20
491 . "'404-790
. i
495 '..,.. 307-843
374 216-489.
467 ,
248-635
434 267-546-;
263 -114-1092 10.3 2.1-20.0 <0.47 <0.30- <0.73
298 43-1121 3.8 0.2- 9.66 <0.75 <0.30- 2.13
113 <40-198 8.9 1.2-16.6 . Cl.15 <0.40- ?.38
226 .10-531 7.3 0.4-26.9 . 2.55 <0.69- 6.75
170 28-304 12.6 0.6-22.2 3.69 <0.68- 6.68
G-7
-------
APPENDIX H
Air Quality Data
-------
TABLE H-l
Glens Falls Annual Wind Frequency Distributions
(in percents)
Wind Velocity Mph
Direction 1-3
N 5.72
NNE 3.63
NE 2.19
ENE 1 . 32
E 0.32
ESE 0.68
SE 1 . 64
SSE 2.76
S 4.50
SSW 2.71
SW 1.40
WSW 1.27
W . 1.47
WNW 1.89
NW 3.26
NNW 5 . 53
Total 40.87
4-7
3.01
2.14
1.94
0.64
0.33
0.42
0.98
2.71
8.43
5.21
1.61
1.55
1.43
0.99
1.27
1.92
34.70
8-12
0.67
0.85
1.21
0.22
0.02
0.00
0.17
0.85
3.98
0.73
0.40
1.41
1.24
0.98
0.45
0.45
13.63
13-18
0.00
0.20
0.11
0.02
0.00
0.00
0.09
0.02
0.43
0.05
0.09
0.17
0.16
0.22
0.00
0.08
1.64
19+
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.11
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.11
Total
. 9.40
6.82
5.45
2.32
1.25
1.10
2.88
6.45
17.34
8.70
3.50
4.40
4.30
4.08
4.98
7.98
90.95
Note:l. Calm = 9.05%.
Source: NYSDEC, 1979.
H-l
-------
Table H-2
Rensselaer Annual Wind Frequency Distributions
(in percents)
Wind Velocity - MPH
Direction 1-3
N 1.59
ME 1 . 62
'NE 0.98
ENE 0.88
E $ 1.89
ESE 2.20
SE 2.18
SSE 2.43
S 5.24
SSW 3.78
SW 2.15
WSW 1.25
W 1.80
WNW 1.40
NW 1.59
NNW 1.15
Total 32.13
4-7
1.50
1.99
0.96
0.27
0.47
2.83
1.82
1.46
4.22
2.60
1.30
1.18
1.95
2.08
3.77
2.37
30.77
8-12
0.42
0.57
0.20
0.08
0.14
2.04
1.44
0.99
3.94
0.97
0.38
1.44
0.94
1.68
4.31
2.01
21.55
13-18
0.13
0.20
0.10
0.06
0.06
0.19
0.22
0.51
2.06
0.24
0.09
0.71
0.33
0.90
4.05
1.13
10.98
19+
0.00
0.04
0.03
0.00
0.00
0.04
0.00
0.09
0.10
0.00
0.01
0.10
0.03
0.24
1.46
0.10
2.24
Total
3.64
4.42
2.27
1.29
2.56
7.30
5.66
5.48
15.56
7.59
3.93
4.68
5.05
6.30
15.18
6.76
97.67
Note: 1. Calm = 2.33%.
Source: NYSDEC, 1979.
H-2
-------
APPENDIX I
Recommended Guideline for PCB Levels in Air
New York State Department of Health
Kim, Nancy K. (written communication). March 25, 1981. Letter from Nancy K.
Kim, Director, Bureau of Toxic Substances Management, State of New York
Department of Health, Albany, New York to Donald Corliss, New York State
Department of Environmental Conservation, Region 5, Raybrook, New York.
Hawley, John, (written communication). March 16, 1981. Letter from John
Hawley, Chief, Bureau of Toxic Substances Management, State of New York
Department of Health, Albany, New York to Italo Carcich, Bureau of
Water Research, New York Department of Environmental Conservation,
Albany, New York.
-------
STATE OF NEW YORK 5
DEPARTMENT OF HEALTH m*> OFFICE OF PUBLIC HEALTH
TOWER BUILDING «
DAVID AXELROD, M.D.
Conimi ssioner
GLENN E. MAUGHIE. M.D.
Di rue. I tit
THE GOVERNOR NELSON A. ROCKEFELLER EMPIRE STATE PLAZA ALBANY. N.Y. 12237
DIVISION OF ENVIRONMENTAL HEALTH
LEO J. HETLING. P.E.. PH.D.
Director
March 25, 1981
Mr. Donald Corliss
DEC - Region 5
Route 86
Raybrook, New York 12977
Dear Mr. Corliss:
Re: Application - Hudson River PCB
Reclamation Project
The attached letters of March 13th and March 16th from John Hawley
of my staff to Italo Carcich constitute the Department of Health's response
to your February 10th request for comments on the above application. This
includes comments on the draft environmental impact statement dated September
1980. I would like to amend one statement in the March 16th letter.
The PCB reclamation program-activates should be designed and carried out
in such a way as to insure that the 24 hour average (not 8 hour average) PCB
concentrations in the ambient air at occupied residences and other sensitive
receptors affected by the activities do not exceed one microgram per cubic
meter (1 ug/rn-^).
Sincerely,
7/7
Nancy TC. Kim, Ph.D.
Director
Bureau of Toxic Substances Management
NKK/pab
Attachments
cc: Mr. Italo Carcich
Steve Arella - EPA
Dr. Hetling
Mr. Smith
Distribution:
Mr. Decker - Northern Area (Albany Office)
Mr. Reilley - Southern Area (White Plains Office)
Mr. Buff - New York City Area
Mr. Baldwin - Oneonta District Office
Mr. Fear - Glens Falls District Office
Mr. Cunnan - Amsterdam District Office
1-1
-------
STATE OF NEW YORK
DEPARTMENT OF HEALTH OFFICE OF PUBLIC HEALTH
TOWER BUILDING THE GOVERNOR NELSON A. ROCKEFELLER EMPIRE STATE PLAZA ALBANY. N.Y. 12237
o»vio AXELROO. M.o. DIVISION OF ENVIRONMENTAL HEALTH
TLINO. ~
Director
C«n-n*...on., - «-EO J. K^TUNO. P.C.. PH.D.
OLENN E. HAUGHIE. M.D.
I'llBcfor
March 16, 1981
Mr, Italo Carcich
Bureau of Water Research
DKC
50 Wolf Road
Albany, New York 12233
Dear Italo:
I would like to add to the comments 1n my letter of March 13th, on the
Jmport.-int topic of acceptable exposure to PCB in ambient nir.
PCB reclamation program activities .should^ be designed ;md carried out in
such a way as to insure that eight hour average PCR concentrations in the ambient
air at occupied residences and other sensitive receptors affected by the
activities do not exceed one microgr.-im per cubic meter (1 ug/m3).
An essential consideration in arriving at this guideline was the limited
duration of the reclamation project. Individuals will, be exposed to these
elevated concentrations for only three or four months in two successive summers.
If you have any further ques-tions; I will be. glad to assist In any way
I can.
Sincerely,
/;
/f
Substi
JoliiV Hawley
Bureau of Toxic Substances Management
JH/pb
cc: Don Corliss - DEC
Steve Arella - EPA
1-2
-------
Ap 15
APPENDIX J
Estimate of Maximum Probable PCB Flux to
the Atmosphere from the Hudson River
Sediment Disposal Basin
DiToro, Dominic M. and Donald J. O'Connor, April 14, 1981.
Estimate of maximum probable PCB flux to the atmosphere
from the Hudson River sediment disposal basin.
Unpublished report, HydroQual, Inc.,
Mahwah, New Jersey.
J-l
-------
I. SUMMARY AND CONCLUSIONS
An analysis of the maximum probable PCB flux to the atmosphere from the
proposed Hudson River Sediment Disposal Basin has been made. In order that an
3
air quality standard of 1 ug/m not be exceeded, the air quality model calcu-
lations done by Malcolm Pirnie Engineers indicate that under critical conditions
2
the emission flux should not exceed 780 ug/m /hr. Similar model calculations
2
by WAPORA indicate a maximum flux rate of 500 ug/m /hr. This report addresses
the probable highest emission flux to be encountered during the dredging opera-
tion.
The volatilization mass transfer coefficient is estimated to be in the
range of K = 0.28 - 0.44 m/day (0.012 - 0.018 m/hr) during critical condi-
tions. The higher value is adopted for this analysis.
An analysis of the behavior of the sedimentation basin indicates that
the maximum dissolved PCB concentration to be encountered is the concentration
which is in equilibrium with the influent sediment mixture. This is the case
regardless of the details of the sediment mixture properties, such as particle
size distribution, settling velocities for particle size classes, etc. For the
critical flux rate and volatilization mass transfer coefficients given above,
the critical dissolved PCB concentrations are C . =43 ug/1 (MPl) or 28 ug/1
(WAPORA). If the critical dissolved concentration is exceeded during dredging
operations, and the critical meteorology occurs as well, then it is computed that
the air quality standard at the nearest receptor of interest could be violated.
The maximum probable dissolved PCB concentration has been estimated by
relating, the sediment PCB concentration and the desorption partition coefficient
to the percent volatile solids in the sediment. Over the range of volatile
solids percentages present in Hudson River sediment to be dredged, the upper
limit of the observed sediment PCB concentration has been established. The
variation of desorption partition coefficient as a function of volatile solids
percentage is less certain. The sparse data available indicates that it is
consistently higher than that which would exceed the critical dissolved concen-
tration of 40 ug/1 but the data are not definitive. In addition the observed
J-2
-------
dissolved PCB concentration from elutriate tests and extrapolated settling tests
exceeded 10 ug/1 in two of the nine cases for which data are available, but did
not exceed 40 ug/1 in any of the cases.
It is concluded that:
The critical dissolved concentration in the basin of 28 to 43 ug/1 will
rarely be exceeded during dredging. However if it is exceeded volatili-
zation can be controlled by adding additional adsorbent to the dredged
material, reducing the equilibrium dissolved PCB concentration and,
therefore, maintain the basin concentration below the critical value.
Before these operational controls are required, additional desorption
tests should be made to determine the likelihood of exceeding the criti-
cal dissolved concentration.
The description partition coefficient data is sparse, and although it
indicates that the critical concentration will not be exceeded, the
quantity of data available cannot rule out the possibility.
The project may proceed, based on the analysis presented below. However,
it is strongly recommended that additional desorption data be obtained
and a more definitive analysis be made.
II. METHODOLOGY
The methodology employed in making the estimates of the PCB flux to the
atmosphere is based upon a mass balance of total PCB within the basin volume.
Since the. principle sink of PCB is via sedimentation of the particulate frac-
tion, an analysis of the sediment solids themselves is required. Let m. (mg/1)
be the concentration of sediment solids entering the basin at a flow rate, Q
(cfs), the basin volume is V, the average depth is H, and the settling velocity
of the solids is V . It is assumed in this analysis that only one size class
of solids is present. Subsequently the analysis is extended to multiple size
classes.
J-3
-------
The mass balance equation for solids states that:
Vdm=Qm. -Qm-vAm (1)
dt X S
where A is the bottom interface area and m is the average solids concentration
within the water column volume.
This mass balance equation applies to a completely mixed volume. Spatial
variation of solids concentration is addressed subsequently. At steady state,
the solids concentration is given by:
1 + K t
s o
where K = v /H, is the apparent first order removal rate (day ) and t
S S O
= V/Q is the hydraulic detention time (day) of the basin.
The mass balance of PCB is complicated by the existence of two forms of
the chemical: the dissolved concentration, C , and the particulate concentra-
tion, C , where these concentrations are expressed as micrograms of PCB per
liter of solution volume. Three mechanisms are considered in this analysis: (1)
adsorption and desorption; (2) sedimentation of the particulate form; and (3)
volatilization of the dissolved form. The latter is the source of concern in
this analysis.
1. Adsorption and Desorption
The principal source of dissolved PCB in the storage basin is from the
desorption of adsorbed PCB. Let R be the rate of PCB desorption (ug/l/day)
and let R be the rate of PCB adsorption. The mass balance equations for
a
dissolved and particulate PCB are:
= QCdi - QCd + VRd + VRa - KLACd
dc
V -H1 = QC . - QC + VR, + VR - V AC
dt pip d a sp
J-4
-------
where K is the surface mass transfer coefficient for PCB (m/day). The key to
the analysis is to consider the total PCB concentration.
CT = Cd + Cp (4)
Adding the mass balance equations yields:
V ~- = QC . - QC - KAC, - v AC
dt XT1XT Ld sp
where the adsorption and desorption kinetic rates cancel.
Since the maximum concentrations are of concern, a steady state analysis is
appropriate. Consider an equilibrium between adsorption and desorption.
Define the particulate PCB concentrations per unit solids concentration,
r (ug PCB/g solids):
r = Cp/m (6)
It has been found that a linear isotherm is appropriate to describe the relation-
ship between particulate and dissolved PCB (see Figure 1, Horzempa and DiToro,
1981).
r =7fCd (7)
where is the partition coefficient (1/g). In fact different partition coeffi-
cients are found for adsorption and desorption with the latter being larger.
Since the concern is with desorption, it is assumed that equation (7) applies for
desorption. Consider the total concentration, c , and express it in terms of
C., and r. That is equation (4) becomes:
d
C = C, + mr (8)
T d
and using the isotherm equation (7) yields:
C = C (1 + m?lO (9)
T d
J-5
-------
so that the ratio of dissolved to total PCB, f , is:
d
f = Id = _ (10)
d CT 1 + mTf
Similarly the ratio of particulate to total PCB is:
C mTT fii^
f = i - f = -J2. (11)
L L * j /i -I , _-.-
p d CT 1 + m^
Since these fractions express the relationships between the dissolved and partic-
ulate concentrations and the total concentration, they may be used in the total
PCB mass balance equation (5) to yield:
V dT - QSi - QCT * Vfd°T - VsAfpCT
and at steady state:
CT.
CT = 1 + t (f K + fK/H) (12)
o p s d L
This equation gives the total PCB concentration in the basin, C , in terms of
the influent total concentration, C,,,., the hydraulic detention time, t , and
Ti o
the removal rates due to sedimentation, K , and volatilization, KT/H, suit-
s L
ably proportioned by the fraction of total PCB that is particulate, f , and
P
dissolved, f, .
d
The dissolved concentration in the basin, C,, is then:
d
Cd = fdCT (13)
and the flux of PCB to the atmosphere, J, is:
J = K_C (14)
L d
Hence the analysis requires an evaluation of equations (12), (13), and (14) with
appropriate values for the coefficients.
J-6
-------
where K is the surface mass transfer coefficient for PCB (m/day) . The key to
Li
the analysis is to consider the total PCB concentration.
CT - Cd + Cp (4)
Adding the mass balance equations yields:
V - = QC . - QC - K AC - v AC (5)
at Ti T L d s p
where the adsorption and desorption kinetic rates cancel.
Since the maximum concentrations are of concern, a steady state analysis is
appropriate. Consider an equilibrium between adsorption and desorption.
Define the particulate PCB concentrations per unit solids concentration,
r (ug PCB/g solids):
r = Cp/m (6)
It has been found that a linear isotherm is appropriate to describe the relation-
ship between particulate and dissolved PCB (see Figure 1, Horzempa and DiToro,
1981).
r =7TC (7)
where is the partition coefficient (1/g). In fact different partition coeffi-
cients are found for adsorption and desorption with the latter being larger.
Since the concern is with desorption, it is assumed that equation (7) applies for
desorption. Consider the total concentration, c , and express it in terms of
C, and r. That is equation (4) becomes:
d
C = Cj + mr (8)
T d
and using the isotherm equation (7) yields:
C = C (1 + m/jO (9)
T d
J-5
-------
so that the ratio of dissolved to total PCB, f,, is:
d
f - V 1 do)
d CT 1 + my
Similarly the ratio of particulate to total PCB is:
C mTf , .
f = 1 - f = _P- = _ (11)
P d CT 1 + m^
Since these fractions express the relationships between the dissolved and partic-
ulate concentrations and the total concentration, they may be used in the total
PCB mass balance equation (5) to yield:
V
and at steady state:
CT.
i
"x 1 + t (f K + f KT/H)
o p s d L
This equation gives the total PCB concentration in the basin, C , in terms of
the influent total concentration, C . , the hydraulic detention time, t , and
Ti o
the removal rates due to sedimentation, K , and volatilization, K /H, suit-
ably proportioned by the fraction of total PCB that is particulate, f , and
P
dissolved, f ,.
d
The dissolved concentration in the basin, C , is then:
d
Cd = fdCT (13)
and the flux of PCB to the atmosphere, J, is:
J " K_C, (14)
L d
Hence the analysis requires an evaluation of equations (12), (13), and (14) with
appropriate values for the coefficients.
J-6
-------
III. SOLUTION
The key to a straightforward analysis of the basin concentration of PCB is
to use the solids mass balance equation solution, equation (2), to evaluate the
settling removal rate coefficient, K . From equation (2) it is clear that:
S
K t = -i- 1 (15)
so m
Consider the denominator of equation (12):
1 + t K f + t f,KT/H (16)
o s p o d L
f I - 1 + t f .K. /H
p V m / o d L
_ i "i-1- t i , i \ *-> ^ (.18)
(m. - m\
] + t 1C /H
m I o L
'J ' (19)
1 + mTT
I + m/T+ mOf - m?T+ t K/H
hr-=2J^- <20)
1 + m a
1 + m.// + t K /H
L (21)
+
1 + raff
The algebraic steps are: substitute for K t , equation (17); substitute for
S O
f and f,, equation (18), cross multiply by 1 + m , equation (19), and
p d
simplify, equation (20) and (21). The result is:
(1 + mTp CT.
CT = 1+ M. + t K/H (22)
1 O L
J-7
-------
Finally, the dissolved basin concentration, C is:
d
_ CT _ CTi (23)
d ~ 1 + m-fl 1 + m/// + t K /H
' 10 L
A further simplification is possible. Note that the dissolved concentration
in the influent is:
c = (24)
and the influent dissolved fraction, f,., is:
di
1
f .. = T-: - ^ (25)
di 1 + m.7/
which is eq (10) evaluated at the influent solids concentration, m. . These
i
expressions can be used to express the dissolved basin concentration, C , in
terms of the dissolved influent concentrations, C,.. The result is:
di
Cdi
Cd = 1 + t f.-K/H (26)
o di L
The remarkable simplification yields the following conclusion: the dissolved
basin concentration, C , is the dissolved influent concentration, C .,
d di
reduced by the loss due to volatilization only. The dissolved basin concen-
tration does not increase due to desorption but rather decreases due to volatili-
zation.
IV. EXPLANATION AND INTERPRETATIONS
This result is somewhat surprising and requires an explanation. Consider
the case for which evaporation is an insignificant loss relative to the basin
mass balance of total PCB. (It may still be important from an air quality point
of view.) Then t f,.K /H « 1 and C, = C .. That is, at steady state,
o di L d di
the dissolved basin concentration is the same as the influent dissolved con-
centra tion. Imagine the following situation: the basin contains initially only
water and no suspended solids. Set the initial condition of the water at the
J-8
-------
influent concentration. This does not affect the final basin concentration since
the initial condition washes out eventually and the steady state concentration is
independent of the initial condition. Now begin the influent so that the parti-
cles begin to enter the basin. Since the dissolved basin concentration is at the
influent dissolved concentration the particles see the same concentration and do
not desorb any chemical. This assumes that the influent is at desorption equili-
brium. This is addressed subseqently. Now the particles settle out. Consider a
single particle settling from the water column to the sediment. The removal of
this particle does not effect the dissolved concentration. Since the other
particles are unaware of its removal, they do not further desorb. Hence the
basin dissolved concentration remains at the influent dissolved concentration.
It is clear from this explanation why the basin dissolved concentration is
independent of particle size effects and varying settling velocities. It does
not matter what size particles settle first since they are in equilibrium with
the dissolved influent concentration. It also does not matter what the state of
contamination of the individual particles is, since they are all in equilibrium
with the influent dissolved concentration and their selective removal by settling
does not change the dissolved basin concentration, so long as it is at the
influent dissolved concentration. Hence the basin achieves the dissolved concen-
tration that is in equilibrium with the influent sediment mixture regardless of
selective removal via sedimentation. The appendix demonstrates this result for
particle specific settling velocities and partition coefficients. Hence the
conclusion is that the basin dissolved concentration will achieve, as a maximum
concentration, the dissolved concentration which is in equilibrium with the
influent sediment mixture. The key to the analysis is, therefore, to make an
estimate of the dissolved concentration which is in equilibrium with the various
sediment mixtures likely to be present in the influent. In addition it is
necessary to estimate the volatilization mass transfer coefficient, KL, and to
review the air quality impact calculations. These latter two tasks are presented,
in the next sections.
J-9
-------
V. VOLATILIZATION RATE OF PCS
The rate at which PCB volatilizes from a basin is given by the product of
the mass transfer coefficients, K (m/day), and the dissolved PCB concen-
i_i
tration, C,. The following analysis follows O'Connor, 1980, 1981. The two
film theory of air-water mass transfer gives the overall transfer coefficient in
terms of the liquid phase transfer coefficient, KI, and the gas phase transfer
coefficient, K (O'Connor, 1980):
O
11+1 (27)
IL = K = HK
L 1 g
where H is the Henry's constant of PCB. The importance of gas phase resistance
depends upon the magnitude of the gas phase mass transfer coefficient, K , and
O
the Henry's constant:
There is considerable uncertainty in the Henry's constant, which in dimen-
sionless units is:
P_ MW (28)
H = 16 C T
s
where P is the vapor pressure (mm Hg), C is the aqueous solubility (mg/1), MW
S
is the molecular weight and T is temperature (°K). Table 1 (Tofflemire and Shen)
given below, lists the results:
TABLE 1
PCB 1242
Solubility
(ug/1)
240
80
340
Vapor Pressure
(mm Hg)
4.1 x 10~£
9.0 x 10 7
3.0 x 10
Henry ' s Cons t ant
(20°C)
0.024
0.16
0.013
J-10
-------
At the critical windspeed of W = 1 m/sec, the gas transfer coefficient for water
evaporation is K = 200 m/day. For PCB a correction is needed for the de-
o
creased diffusivity of the larger molecule using the ratios of the molecular
weights to the 1/2 power yields. K = 53 m/day for PCB 1242. The factor
O
HK , therefore, is in the range of HK = 0.69 - 8.5 m/day.
O O
For the liquid phase transfer coefficient, KI ) two regions of the basin
are considered: the region near the basin influent where water velocities are
high, and the remaining region where wind velocities determine K . The size of
these regions are chosen to be 100 m x 100 m to be consistent with the air
quality analysis.
4 2
For the influent region, it is estimated that over the 10 m region the
average water velocity is 0.5 ft/sec (R. Thomas, Malcolm Pirnie, 1981 personal
communication).
The liquid film mass transfer coefficient is given by:
1/2
(29)
where D is the molecular diffusivity of PCB, V is the velocity and H is the
J_j
depth. A correlation to molecular weight (MW) is available to estimate the
diffusivity of PCB:
-4 -2/3
DT = 2.2 X 10 (MW) (cm /sec)
Li
=5.43 X 10 cm2/sec (30)
For a basin depth of H = 10 ft in this region the resulting transfer coef-
ficient is:
Kx = 0.45 m/day (31)
J-ll
-------
For the other regions the water velocity is negligible and the wind velocity
controls. The liquid phase controlled transfer coefficient is given by:
(,32)
where C is the drag coefficient, V is the kinematic viscosity of water, W
D L
is the wind velocity, p /p is the ratio of air to water density and /L is
aw 2.
related to the viscous sublayer fetch, and height of the waves. For low wind
2
speeds, C, = 0.0016, = 6. The kinematic viscosity is = 0.01 cm /sec,
fl *L J_i
P /P = 0.0012 so that:
a w
KI = 0.46 m/day (33)
at a wind velocity of W = 1 m/sec. Since both these transfer coefficients are
essentially the same, a transfer coe
this analysis independent of location.
essentially the same, a transfer coefficient of KI =? 0.46 m/day is used for
The overall transfer coefficient, including both gas and liquid phase
resistances is:
KT = 0.28 to 0.44 m/day (34)
Li
depending upon which gas phase transfer coefficient is used. In order to be
conservative, the upper value of K = 0.44 m/day is adopted.
VI. FLUX RATE OF PCS AND AIR QUALITY IMPACT
The flux rate of PCB is given by:
J = K C.. (ug/m2/hr)
3
10 1 1 day
= 0.44 m/day ' Cdi (ug/1) ' m3 x ^ ^
= 18.3 C . (Ug/m2/hr) (35)
di
for C . in ug/1.
J-12
-------
The air quality impact at the nearest receptor can be calculated from the
analysis made by WAPORA. For the five cells (100 x 100 m) in an axis with the
nearest receptor the air concentrations resulting from an emission rate of J =
3 2
10 ug/m /hr are given in Table 2.
TABLE 2
Cell No.
17
16
15
14
13
Total
Receptor Concentration
(ug/m )
0.336
0.312
0.198
0.252
JK168
1.27
An independent air quality assessment was made by Malcolm Pirnie Engineers.
2
For an emission rate of 158 ug/m /hr they compute a receptor air concentration
3 32
of 0.2 ug/m . For J = 10 ug/m /hr their result would be C . = 1.26
3
ug/m which is in close agreement with the WAPORA results. Therefore the
nearest receptor air quality concentration, C . , is given by:
3.1 r
1.27 (ug/m3)
C . = ... , , 3/u ,. x 18.3 C,. (36)
air 103 (ug/m /hr) di
= 0.0232 CJ.
di
3
For an air quality standard of C . =1 ug/m the dissolved influent concentra-
311*
tion C,. must not exceed:
di
C . max = 43 ug/1 (37)
J-13
-------
Hence the air quality standard at the closest receptor of interest is not ex-
ceeded if the equilibrium dissolved influent concentration does not exceed
C . 40 mg/1. The factors that control the concentration are discussed in the
next section.
VII. PROBABLE MAXIMUM DISSOLVED PCB CONCENTRATION IN THE BASIN INFLUENT
It has been shown previously that the dissolved concentration in the basin
reaches the influent equilibrium dissolved concentration at steady state. The
volatilization and air quality analysis indicate that dissolved concentrations in
excess of 40 ug/1 violate the standard for critical conditions. The problem
is to estimate the highest probable dissolved influent concentration to be
encountered in the dredging program. This analysis is complicated by the vari-
ability of the sediment properties and degree of contamination.
The approach taken in the analysis presented below is to index the sediment
by the percent volatile solids it contains. The relationship between sediment
PCB concentration and percent volatile solids is shown in Figure 2. The upper
line on the figure represents the assumed upper bound of sediment PCB concentra-
tion to be encountered during the dredging operations.
In order to estimate the equilibrium dissolved concentration as a function
of percent volatile solids, the desorption partition coefficient is required.
Some data are available which can be used to estimate the equilibrium
dissolved concentrations to be expected. Elutriate experiments have been con-
ducted on various Hudson River sediment samples (Tofflemire, 1981). A four part
water to one part sediment mixture is equilibrated for one hour. Desorption
experiments conducted at Manhattan College using Saginaw Bay sediments indicated
that equilibrium is achieved in less than 15 minutes so that it is reasonable to
assume that the elutriate tests are at equilibrium. The results are shown in
Table 3 (Tofflemire, 1981). The unfiltered samples are included for completeness
but are ignored in this analysis since it is not possible to estimate the dis-
solved concentration in the supernatant without an actual solids separation.
J-14
-------
TABLE 3
Elutriate Test Data
Location
1.
2.
3.
4.
5.
6.
7.
E. Channel Ft.
it
Buoy 212-214
Lock 1
Albany Port
Germantown
Albany Turning
Basin
Rt. 4 Bridge
Bouy 202
Bouy 214
Mosseskill
ii
Buoy 210
Thompson Isl
ii
% Silt
-
< 5
5.4
12
0.5
< 4
75
2
1.5
< 11
65
20-60
17
20-60
44
% Volatile Sediment PCB Dissolved
Solids ug/g PCB (ug/1)
(30% wood) 25.6
20.0
6 35
5-24 13
2.44 0.08
1.35 0.08
6.84 3.5
Unfiltered Samples
6 20-30
57.1
2 45.6
-20 191
30-50
149
246
7 293
19.3
1.5
6.6
0.3
0.06
0.04
0.09
Supernatant
PCB (ug/1)
9.9
61.6
49
1
20
196
138
78
Partition
Coefficient
(1/g)
1.3
13.0
5.3
43.0
2.5
2.0
39
2.5
0.93
0.93
190
2
0.76
1.8
3.8
J-15
-------
The resulting partition coefficients versus percent volatile solids are
shown in Figure 3. Saginaw Bay data are included to provide some additional
information (Horzempa and DiToro, 1981). The line on the figure represents the
partition coefficient which, together with the assumed upper bound of sediment
PCB (Figure 2) achieves an equilibrium dissolved concentration of C,. = 40
di
ug/1. Although the data are quite sparse, the observed partition coefficients are
all in excess of the critical values represented by the line in Figure 2.
However at the low volatile solids percentages (1 to 3% volatile solids) the
observed partition coefficients are close to critical. It is clear that more
data are required for a definitive analysis.
Figure 4 presents the observed dissolved PCB concentration from the elutri^
ate tests (the circles) versus percent volatile solids. Extrapolated dissolved
concentrations from settling tests (the squares) are also presented. Note that
two samples exceed 10 ug/1 of dissolved PCB. This is uncomfortably close to the
critical concentration of 40 ug/1.
The conclusion from this analysis is that although it appears probable that
the critical concentration of 40 ug/1 will not be exceeded with any regularity it
is possible that occassional higher concentrations may occur. Therefore miti-
gating measures should be investigated. In addition more systematic elutriate
test data, consistent with this analysis should be collected in order to rein-
force the conclusions drawn.
VIII. CONTROL MEASURES
The analysis presented in this report suggests that the controlling variable
is the equilibrium dissolved concentration in the influent. Any method which
reduces this concentration would reduce the air quality impact proportionally.
The most direct method would be to introduce an additional adsorbent (e.g. fine
clay or activated carbon) into the dredged sediment. This would increase the
partition coefficient of the mixture of sediment and adsorbent and therefore
reduce the resulting dissolved concentration. The details of the required
quantities of adsorbent and the optimal location for its introduction can be
addressed subsequently if the additional elutriate tests indicate that low
partition coefficients and highly contaminated sediments occur simultaneously to
any significant degree.
J-16
-------
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4)
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b
05
PH
Adsorption
Desorption
3o
Aqueous Concentration, c, (ng/£)
Figure 1
J-17
-------
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10/M
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J-18
-------
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J-19
-------
TEST
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J-20
-------
Appendix j.l
Analysis for Particle Specific Settling Velocities and Partition Coefficient.
I. Equations and Solutions.
For an influent sediment mixture of k=l,2,...,N classes of distinct
particles let m., be the influent solids concentration, m,. be the basin
IK K
concentration, and K , - V ,/H be the apparent removal rate of particles of
class k. Then at steady state:
mik
"k " l+Kgkto (Al)
The mass balance equation for total PCB is:
dCm H
\1 fc- J. * J- U \* m ~ SIC P^
Where C , is the particulate concentration of PCB on the k particle class.
pk
For each particle class, let
rk - ,k C, (A2)
Where IT, is the partition coefficient for the k class. Then:
N
CT = C + ^_ DLT (A3)
1 a tc=i
or:
N
"he Uk (A4)
N
(A5)
so that:
fd = -pr- = , . ^ . (A6)
tl \j.
J-21
-------
The particulate fractions for each of the k classes is:
k k
CT CT CT cd
nL 17
(A7)
1 +£_m 17
n
Where the denominator summing index is changed to n for clarity. Hence the
total PCB concentration mass balance equation is:
dCT N
V ~aT = Q CTi ~ Q CT ~ \ A Cd ~ £. Ksk A Cpk (A8)
Q CT. - Q CT - ^ A fd CT - A CT 2. Ksk fpk
and the steady-state solution is:
C,
Ti
(A9)
1 + t (f . K/H + > f . K . )
o d L ^r- pk sk
The denominator can be simplified as:
1 + t (f. K./H) + t £_ f . K .
odT, o~-pksk
m. 17, / m., m, \ t k, .
/ k. k I ik K. \ o d f 1
k l+5mi7 V m, I H 1 +^m 17
^ nn \ "k / ^ nn
(All)
1 + > m 17 + ^_ m., 17. - ^_ m. 17. + t K./H
fc- n n " ik k ~ K. k o d
(A12)
1 + __ m 17
n
J-22
-------
a..ir. + t K,/H
, ik k o d
(A13)
m ir
** n n
n
so that the steady state solution is:
S = ~
1 +5'mj,tTk + t K./H (A14)
T- ik o d
The dissolved basin concentration is:
fd CT = ' (A15)
^- n n
n
CTi
k
which can be expressed as:
CHi
-£± (A16)
1 + t f.IL/H
o d L
where:
Cdi = TT ' fdCTi (A17)
is the dissolved influent concentration. Thus the dissolved basin concentration
is the dissolved influent concentration, reduced by the loss via volatization,
and independent of the specific settling velocities, particulate concentrations,
and partition coefficients of the classes of particles in the influent.
J-23
-------
REFERENCES
Bopp, R., 1979. Ph.d. Thesis. Columbia University, N.Y.
Horzempa, L., DiToro, D. M., 1981. The Extent of Reversibility of Polychlori-
nated Biphenyl Adsorption, Manhattan College, in press, Water Research.
O'Connor, D. J., 1981. The Effect of Winds on the Mass Transfer Coefficient of
Organic Chemicals. Manhattan College Progress Dept. to EPA Gulf Breeze Lab.
O'Connor, D. J., 1980. Manhattan College Summer Institute Notes, Manhattan
College, Bronx, N.Y.
Pirnie, Malcolm, 1980. PCB Hot Spot Dredging Program Containment Site. For N.Y.
State Dept. Envir. Cons.
Tofflemire, T. J., 1981. PCB Volatilization. Memo, N.Y. State Dept. Envir.
Cons.
Tofflemire, T. J., Shen, T. T. Volatilization of PCB from Sediment and Water.
Experimental and Field data, N.Y. State Dept. Envir. Cons.
J-24
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