Urted States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-84/004
September 1984
Superfund
Record of Decision:
Hudson River RGBs
Site, NY
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA/ROD/R02-84/004
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Hudson River PCBs Site, NY
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
SPONSORING AGENCY NAME AND ADDRESS
:.S. Environmental Protection Agency
01 M Street, S.W.
ashington, D.C. 20460
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
09/2S/P4
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
SUPPLEMENTARY NOTES
ABSTRACT
During a 30-year period ending in 1977, the Hudson River was contaminated with
olychlorinated biphenyls (PCBs) from two capacitor manufacturing plants owned by
ne General Electric Company. Field surveys have shown that PCB contamination is
ound in 40 submerged sediment hot spots, 5 exposed shoreline remnant deposits,
iredge spoils on the banks of the upper Hudson River and in estuary sediments.
The remedial alternative selected for this site consists of in-place contain-
,ient of remnant shoreline deposits. This temporary solution includes: covering
.ffected areas with an 18-inch thick layer of subsoil followed by a 6-inch layer of
.opsoil, grading and seeding the cover to minimize erosion and, if necessary, bank
-tabilization to prevent scouring. An alternative to address submerged PCB hot spots
.•as not selected at this time because of the lack of existing data to establish that
existing technology would be effective and reliable. The State will conduct a
-redging demonstration program using funds from Section 116 of the Clean Water Act.
.f adequate, the information from this demonstration project will be used to develop
.1 remedial action which will address both river sediments and the exposed remnant
deposits.
Key Words: Dredging, No Action Alternative, PCBs, Containment, Direct Contact,
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Record of Decision
Hudson River PCBs Site, NY
Contaminated media: sw, dredge spoils,
river sediments
Key contaminants: PCBs
18. DISTRIBUTION STATEMENT
b.lDENTIFIERS/OPEN ENDED TERMS
None
20. SECURITY CLASS (TIlis page!
None
c. COSATI Field/Group.
AC.
22. PRICE
EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE
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ROD ISSUES ABSTRACT
Site: Hudson River PCBs Site, New York
Region; II
AA, OSWER
Briefing Date; June 6, 1984
SITE DESCRIPTION
During a 30-year period ending in 1977, the Hudson River was
contaminated with polychlorinated biphenyls {PCBs) from two capaci-
tor manufacturing plants owned by the General Electric Company.
Field surveys have shown that PCB contamination is found in 40 sub-
merged sediment hot spots, 5 exposed shoreline remnant deposits,
dredge spoils on the banks of the upper Hudson River and in estuary
sediments.
Selected Alternative
The remedial alternative selected for this site consists of
in-place containment of remnant shoreline deposits. This temporary
solution includes: covering affected areas with an 18-inch thick
layer of subsoil followed by a 6-inch layer of topsoil, grading and
seeding the cover to minimize erosion and, if necessary, bank
stabilization to prevent scouring. An alternative to address sub-
merged PCB hot spots was not selected at this time because of the
lack of existing data to establish that existing technology would be
effective and reliable. The State will conduct a dredging demon-
stration program using funds from Section 116 of the Clean Water
Act. If adequate, the information from this demonstration project
will be used to develop a remedial action which will address both
river sediments and the exposed remnant deposits.
ISSUES AND RESOLUTIONS KEY WORDS
1. No remedial action will be taken for the . Dredging
Hudson River PCB sediments to mitigate the . No Action
primary route of exposure through the Alternative
environment (consumption of PCB contami- . PCBs
nated fish). Because the effectiveness of
available technologies to.dredge PCB con-
taminated sediments in a dynamic, riverine
environment is not known, a cost-effective
alternative was not selected. The infor-
mation generated from the State's demon-
stration dredging program may be used to
develop future remedial measures.
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Hudson River PCBs Site, New York
June 6, 1984
Continued
2. In-place containment of remnant PCB deposits . Containment
exposed on the shoreline was selected as a . Direct Contact
temporary remedial measure until future . PCBs
remedial actions are developed which ad- . Temporary Remedial
dress PCB contaminated sediments. This Measure
temporary remedial measure will be effec- . Volatilization
tive in mitigating the primary public expo-
sure pathways of direct contact and
volatilization.
3. The option of bank-to-bank dredging of the . Dredging
river was rejected because of the severe . Environmental
damage it would cause to the river ecosystem. Impacts
This option was, therefore>not considered
adequate to protect the environment.
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RECORD OF DECISION
Remedial Alternative Selection
Site: Hudson River PCBs Site; Glen Falls, New York
• *
Documents Reviewed;
I am basing my decision primarily on the following
documents describing the analysis of cost-effectiveness
of remedial alternatives for the Hudson River PCBs Site:
Feasibility Study - Hudson River PCBs Site,
New York, NUS Corporation, April 1984.
Staff Summaries and Recommendations.
Responsiveness Summary dated September 1984.
Description of Selected Options;
In-place containment of the remnant deposits by
application of a soil covering followed by vegetation.
In addition, banks currently unreinforced will be
stablized and fences will be erected where appropriate
to prevent public access.
Evaluation of downstream domestic water quality at
Waterford, New York and assessment of various treatment
upgrading options if appropriate.
Declarations;
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 CFR Part 300), I have determined in-place
containment of the PCB contaminated remnant deposits is a cost-
effective method to effectively mitigate the most significant
threats to health and the environment posed by the remnant deposits,
The State of New York has been consulted and agrees with the
approved remedy.
I have determined that a technologically feasible, cost-
effective remedial response to PCB contamination in the riverbed
that would be reliable and would effectively mitigate and minimize
damage to public health, welfare and the environment is not
presently available.
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I have determined that the action taken is appropriate when
balanced against the availability of Trust Fund monies for use at
other sites. I have also determined that the off-site action of
monitoring the downstream water quality at Waterford and assessing
the adequacy of its water treatment facility is consistent with
the goals and objectives of CERCLA to protect public health,
welfare and the environment.
/ Datfe
M. Thomas, Assistant Administrator
Office of Solid Waste and Emergency Response
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Summary of Remedial Alternati ve Select ion
Hudson RiveV~PCB_s_j>.ite
New York
Sit^e I^cation and Descr ipt ion: (see Figures 1 through 3)
The Hudson River originates in the Adirondack Mountains in
Essex County, New York, and empties into the Atlantic Ocean at
the Battery in New York City. The river's 17 major tributaries
drain 13,365 square miles of land located in eastern New York
State and in parts of Vermont, Massachusetts, and Connecticut.
The lower river, from its mouth in the upper New York Harbor to
its confluence with the Mohawk River near Albany, is a tidal
estuary subject to periodic fluctuations in water level. This
150-mile reach is maintained and regulated as a Federal waterway
by the U.S. Army Corps of Engineers to provide waterborne access
to the Port of Albany and the New York State Barge Canal. The
river above Albany is a high gradient, fresh water stream confined
by 15 dams. The 30-mile reach between Albany and Fort Edward is
officially under the jurisdiction of the New York State Department
of Transportation (DOT).
Site H i_s t OJT y:
Over a 30-year period ending in 1977, two General Electric
(G.E.) capacitor manufacturing plants near Fort Edward and Hudson
Falls, New York discharged polychlorinated biphenyls (PCBs) to
the Hudson River. Much of the PCBs in the discharges was trapped
in sediments behind a 100-year-old dam at Fort Edward. After
the removal of the dam in 1973, large spring floods scoured an
estimated 1.5 million cubic yards of material from the former
dam pool. Subsequent studies have revealed that the discharges,
in combination with the removal of the Fort Edward Dam, have
ultimately resulted in the dispersal of approximately one million
pounds of PCB throughout the entire Hudson River system south of
Fort Edward. Today, much of this PCB has either been dredged or
washed out to sea so that only 498,000 to 656,000 pounds remain
in the river. G.E. is also reported to have placed an additional
528,000 to 745,000 pounds of PCB in upland dumps. These PCBs
are not directly related to the Hudson River problem (see Tables
1 and 2). The estimates above represent ranges extracted from
various studies.
Action brought against G.E. by the New York State Department
of Environmental Conservation (NYSDEC) in 1975 resulted in a
$7,000,000 program for the investigation of PCBs and the develop-
ment of methods to reduce or remove the threat of PCB contamin-
ation. Subsequent sediment surveys revealed that the most exten-
sive contamination was confined to 40 submerged PCB hot spots
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located in the river between Fort Edward and Albany, and to five
exposed remnant deposits located in the former dam pool. PCBs
were also found to exist in dredge spoils on the banks of the
Upper Hudson River and in sediments of the estuary. Other
monitoring data showed that minor quantities of PCBs were being
released from river-bottom sediments to the water column and to
the air and land adjacent to the river. The detection of PCB
contamination in Hudson River fish resulted in a State-mandated
ban on all fishing in the Upper Hudson River between Albany and
Fort Edward, and in restrictions on commercial and recreational
fishing in the Lower Hudson. In addition, it was feared that
the continued presence of PCBs might disrupt dredging activities
needed to maintain the barge canal and Federal waterways and
might curtail the development of the river for hydroelectric!ty.
For these reasons, NYSDEC proposed a partial cleanup of the
river by dredging selected PCB hot spots (areas of relatively
high PCB contamination, generally between 50 and 500 ppm) and
containing the contaminated material in a secure upland contain-
ment facility.
Current Status;
In September 1980, Congress passed an amendment to the
Clean Water Act (CWA) under Title 1, Section 116(a) and (b),
entitled, "The Hudson River PCB Reclamation Demonstration Project."
Under this legislation, construction grant funds up to $20,000,000
could be authorized by the EPA Administrator if he determined
that funds were not first available under Section 116 or 311 of
the CWA or from the then-proposed CERCLA. Congress authorized
EPA to make grants to the NYSDEC in order to carry out the intent
of the Act. The funding authorization was due to expire on
September 30, 1983, but has since been extended (See Attachment 1).
The Hudson River Sloop Clearwater and other environmental
groups and New York State brought suit to compel EPA to award the
balance of $20 million under Section 116 of the Clean Water Act
for the Hudson River Reclamation Demonstration Project. The
parties agreed to a court order extending the September 30, 1983,
expiration date of Section 116 funding. In March, 1984, EPA
released funds provided under an earlier grant for the hot spots
verification. On May 10, 1984, EPA entered into a settlement
agreement with the plaintiffs. Under the terms of the agreement,
EPA will make a grant to New York of approximately $18 million
for dredging and disposal of PCBs if the State obtains an acceptable
disposal site with all necessary State and federal permits within
three years. The lawsuits were dismissed.
As a result of federal involvement and in accordance with
the National Environmental Policy Act (NEPA) and requirements in
Section 116, EPA Region II, on May 8, 1981, issued a Draft Environ-
mental Impact Statement (EIS) on the Hudson River PCB problem.
This was followed by a Supplemental Draft EIS on August 18,
1981. After review of the Final EIS (issued October 8, 1982),
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the NEPA process was concluded on December 30, 1982, with a Record
of Decision in which the EPA Administrator determined that funds
for addressing this problem were available under CERCLA and that
the problem rated sufficiently high to be considered for inclusion
on the National Priorities List (NPL).
A Remedial Action Master Plan (RAMP) was initiated in May
1983 to evaluate all available information and assess feasible
remedial options consistent with the National Contingency Plan.
Before the RAMP was completed, the Hudson River PCBs Site was
placed on the EPA's proposed NPL and, as a result, became eligible
for CERCLA funding. The RAMP was subsequently changed to a
feasibility study since the elements necessary in such a study
were already incorporated within the RAMP document.
A draft Feasibility Study report was completed in September
1983 and became available to the public for a thirty (30) day-
review period starting October 7, 1983. Due to requests received
at the public meeting held in Albany, New York on November 3,
1983, the comment period was extended to November 30.
The majority of the information used in this study was
generated as a result of a 1977 sampling effort conducted by the
NYSDEC, This sampling program established the hot spot locations.
A limited amount of sampling was performed at selected hot spots'"
in August 1983, by EPA. The 1983 data,-when compared with the
1977 survey results, suggested that some hot spots may have
shifted, while others stayed in place.
This summer NYSDEC staff have conducted an intensive sediment
survey in the Thompson Island Pool. The purpose of the survey
is to confirm the presence of PCB hot spots in the Upper Hudson
River sediment and to identify their boundaries for dredging
design purposes. In addition to the survey, the CWA Section 116
grant will fund the United States Geological Service's annual
water monitoring, development of a DEC caged fish monitoring
program, and DOH macroinvertibrate studies in the Upper Hudson
River. Grant funds will also pay for a sediment erodibility
study, a PCB transport study, and a PCB volatilization study.
Enforcement;
On May 5, 1983, EPA met with G.E. representatives to discuss
the Agency's intentions of listing the Hudson River PCB Site on
the NPL and to pursue negotiations with the company. The site was
subsequently listed on the September 8, 1983 proposed NPL update.
On October 27, 1983, EPA issued a Notice Letter to G.E. as a
responsible and liable party. This letter notified G.E. of EPA's •
intentions to conduct a predesign sampling program and implement
the remedial alternatives unless the company agreed to do so
itself.
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G.E. responded to this letter by calling EPA's notice
premature and unjustified. First. G.E. objected to the fact
that EPA issued a notice letter for a site that is not on the
NPL; and second, the company did not recognize a threat caused
by the site to human health or the environment.
EPA has responded to G.E.'s letter by stating that remedial
planning activities can be undertaken for a site on__tjie__p_ropjosed
list. EPA may issue an 6rder to the company for remedial design
and cleanup. EPA also discovered that the Niagara Mohawk Power
Corporation may also be a site owner and responsible party. A
notice letter was issued on February 29, 1984, to Niagara Mohawk,
and an order will be issued if it is determined that the company
is a responsible party. Niagara Mohawk, which utilizes the
Hudson River for hydroelectric power, received a permit to remove
the dam located in Fort Edwards, which eventually resulted in
the formation of the hot spots downstream.
Alternative Evaluation:
The major objective of the feasibility study was to evaluate
remedial alternatives using a cost-effective approach consistent
with the goals and objectives of CERCLA. A cost-effective remedial
alternative is defined in the National Contingency Plan (NCP)
(40 CFR 300.68(j) as "the lowest cost alternative that is techno-
logically feasible and reliable and which effectively mitigates "
and minimizes damage tQ and provides adequate protection of public
health, welfare, or environment." The NCP outlines procedures
and criteria to be used in selecting the most cost-effective
alternative.
The first step is to evaluate public health and environmental
effects and welfare concerns associated with the problem. Criteria
to be considered are outlined in Section 300.68(e) of the NCP
and include such factors as actual or potential direct contact
with hazardous material, degree of contamination of drinking
water, and extent of isolation and/or migration of the contaminant.
The next step is to develop a limited list of possible
remedial actions which could be used. The no-remedial-action
alternative must be included on the list. Included were alter-
natives previously examined in the EIS and additional actions
such as treatment of public water supplies. A number of new PCB
treatment and destruction technologies were also reviewed to
ensure that all reasonable alternatives were considered.
The third step in the process is to provide an initial screen-
ing of remaining alternatives. The costs, possible adverse effects,
relative effectiveness in minimizing threats, and reliability of
the methods are reviewed. This analysis requires a more detailed
estimation of costs and engineering implementation and a closer
assessment of the ability of alternatives to minimize or mitigate
threats. In this study, the detailed analysis was aided by a
cost-effectiveness matrix which was developed by independent
consultants under the direction of EPA.
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Alternatives were broken down into two specific categories
for evaluation. These were:
o River sediment alternatives
o Remnant deposit alternatives
A list of potential feasible alternatives has been assembled
in Table 3, and associated costs have been provided.
Based on the analysis described above, the various categories
of alternatives were evaluated, and the following conclusions
were .reached:
River Sediments
As outlined in the previous section, an alternative evalua-
tion was initiated to determine which technologies would provide
adequate protection to public health and the environment from
the major contaminant pathways. The primary pathways that
threaten public health are the ingestion of contaminated fish
and the contaminat-ion of municipal drinking water systems. The
spread of contamination to both of these pathways has not been
fully quantified, since the PCBs are concentrated in the River
sediment and the mechanisms of transport from the sediment to the
water column and/or fish are poorly understood. Although studies
of the river system are continuing, sufficient data to support a
no-action alternative as the permanent recommended alternative
are not available at this time.
Therefore, Numerous alternatives were assembled which
potentially addressed the river sediment problem. Included
in this list were various new technology options for in-river
detoxification such as degradation by ultraviolet light, ozoni-
zation, chemical treatment, bioharvesting and activated carbon
adsorption. In addition, in-river containment methods were
analyzed for both shallow 'deposit locations and areas of high
deposition.
While new technologies were explored in detail within the
study, the majority of these options, though appealing, were
dropped from consideration due to limited testing or lack of
availability. These new technologies may be proven in the near
future under more controlled circumstances (i.e., the OMC site)
or under other types of study efforts (i.e., the CWA Section 116
demonstration project). Upon the successful completion of these
types of projects, the recommendations presented in this document
may very well need to undergo reevaluation and possible revision.
An evaluation of the treatment technologies indicated that
although all of the technologies proved to be useful—or
potentially so—in removing PCBs from oils, not all of the
treatment methods could be used in connection with PCB-
contaminated sediments. Some of the treatment technologies
were found to be applicable for sediment decontamination,
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but only two processes, KOHPEG and NaPEG, were found to be
potentially applicable as an in-situ solution. For the other
treatments, the sediments must first be exposed (by dredging or
by river level reduction) and treated after dewatering.
Unfortunately, even the KOHPEG and NaPEG processes are
still in the early stages of development, with little information
being available on their'environmental effects and costs. For
this reason, these alternatives were dropped from further consid-
eration at this time. Such new technologies listed above may
prove not only reliable but practical at some point in the future,
and might be available to address PCB problems which may exist
in the Hudson River at that time.
Ip-river containment was evaluated in relation to other
options available. It was determined that the initial costs
associated with containment were comparable to a dredging option,
however, the maintenance costs would be perpetual and, therefore,
restrict!vely high. Also, the capping of contaminated deposits
in a river "system offers numerous technical and maintenance
problems.
In addition, it is likely that even if technical problems
can be resolved, installation of an artificial cover could result"
in a short-term disturbance(by less-contaminated sediments) of
the contaminated sediments and their existing natural cover. In
turn, this may substantially increase the contamination in the
water column for some time thereafter. Finally, although an
artificial cover could in theory decrease the overall long-term
release of PCBs into the Hudson River environment, the marginal
increase in protection (as compared to the natural sediment cover
which now exists) will be considerably outweighed by the very
high cost of such an action. For these reasons, this alternative
was removed from further consideration.
EPA also evaluated the option of bank to bank dredging of
the entire river. This alternative would remove the bulk of the
PCB's on the upper river and therefore would be most effective in
reducing the long-term public health and environmental threats
from PCB exposure (although significant amounts of PCB's would
be released into the water column in the short term). However,
bank to bank dredging could be environmentally devastating to
the river ecosystem and cannot be considered to adequately
protect the environment.
In addition, even if the negative impacts could be eliminated,
disposal of this quantity of contaminated sediments would require
an impractically large containment facility. Finally, the cost
of the bank to bank dredging alternative, given the level of risk
presented even if the Agency takes no action, would appear to be
excessive given the need to respond to other sites which may
present threats to public health, welfare, and the environment.
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EPA also evaluated two additional options which involved
dredging a number of "hot spots" in the upper river basin. The
full scale hot spot alternative would involve the dredging of 40
hot spots, and the more limited option would address 20 hot spots.
These programs would remove an estimated 28-46% of the PCBs in
upper river sediments, and an estimated 18-29% of the PCBs in
the entire river. PCBs are ubiquitous in low concentrations
throughout the river system, and the hot spot program would not
address these low concentration areas. Furthermore, it is not
clear that elimination of 28-46% of the PCBs in the river system
would result in an equivalent decrease in the total amount of
PCBs released from river sediments into the water column. It is
possible that the rates of release in the environment are related
to the exposed contaminated surface area of the river bed, and
the hot spots constitute only about 8% of the affected area in
the upper Hudson River Basin.
Modeling indicates that removal of the hot spots would
have some positive effect on the river environment. One model
produced an estimate that for the 40 hot spot dredging
alternative it would take approximatly 46 years for PCBs in the
Upper Hudson River to be fully depleted. Under the no action
option for the river sediments, this model indicates that the
PCBs in the upper river would be fully depleted in approximately
64 years (these time periods should only be considered indicative
of the relative benefits of the no-action and hot spot options,
since there are considerable uncertainties in the models).
Furthermore, the times given refer to total depletion of PCBs,
and it is likely that some level short of total depletion can be
considered to provide adequate protection of public health and
the environment. For example, although individual fish still
may be highly contaminated with PCBs, the average level of
contamination has declined below the FDA limit, and this
decrease is expected to continue.
The above figures on the amount of PCBs which would be
removed by hot spot dredging assume that a very high percentage
of the PCBs in the hot spot areas would be controlled. However,
the technology and methodology of this type of dredging in a
dynamic, riverine environment is unproven and uncertain. Dredging
activities by their nature tend to result in some degree of
disturbance of the highly contaminated sediments, and thus result
in some short-term problems, in the form of elevated PCB concent-
rations in the water and air, as well as increased fish contamin-
ation. Because the technology for reducing the disturbance of
the sediment or controlling the spreading of the suspended materials
is unproven in this type of a situation, it is difficult to
estimate reliably the amount of the contamination which will be
recovered or, on the other hand, the level of short-term damage
which may result from releasing the PCB materials into the water
column. Therefore, it is difficult to conclude at this time
that the technology can be considered feasible or reliable.
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The estimated.cost of the limited and full-scale hot spot
dredging alternatives is $34,000,000 and $55,000,000 respectively,
assuming that a secure containment area could be constructed in
the vicinity of the dredging site. However, the likelihood of
such a 'site being available in the near future is highly question-
able. Disposal of the wastes at the closest currently available
site would increase the cost by as much as $200 million. (See
PCB Disposal Alternatives discussion, below).
Finally, EPA evaluated the no-action alternative. This
alternative could result in leaving 500 thousand pounds of PCBs
in the river system . Natural on-going sediment transport
mechanisms within the river have covered many of the PCB contam-
inated areas (hot and cold spots) with a less contaminated sediment
layer, which significantly reduces the migration of PCBs in the
water column and exposure to aquatic life.
Based on reviews of current data, the average level of
contamination of -Hudson River fish has declined below the FDA
limit of 5 ppm although highly- contaminated individual fish are
still found in both the Upper and Lower Hudson. Consumers of
fish are warned of exposure by NYSDEC restrictions that have been
in effect since 1976. While the fish consumption limitation
suggested by the ban certainly is not a solution to the problem,
it does offer some level of protection. It is important to note
that detectable levels of dioxin, dibenzofurans, mercury and
chlordane (from known and unknown sources) have also been identi-
fied in Hudson River fish, and that even if PCBs decrease to an
acceptable level, the fishing bans would continue on the basis
of these other types of contamination. The enforcement of the
fishing bans and the continued monitoring of the contamination
should reduce the threat to consumers while the fish population
continues its natural recovery during the interim evaluation
period. It is projected that the natural assimilative capacity
of the river will continue the downward trend in the levels of
PCBs found in the river.
Concerns have also been raised regarding the effect of the
no-action alternative on future ocean disposal of the dredged
sediments generated during periodic river maintenance operation.
Past conclusions about the problems with ocean disposal of dredged
sediments may be misleading. The Draft Environmental Impact
Statement indicated that, if certain unusual conditions were to
occur, the PCB concentration of harbor sediments would continue
to increase to a level above disposal limits and thereby restrict
ocean disposal. This projection assumed that all of the PCBs in
the Upper Hudson would reach the harbor in 64 years and that the
dredging rate would remove at least a constant 4000 pounds of
PCB per year (assuming sediment concentrations would either remain
the same or increase).
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It is now recognized that recently deposited harbor sediments
are lower in PCB content than older sediments. Since dredging
generally removes only the most recently deposited material,
ocean disposal of dredged material should not be adversely impacted.
If present conditions continue, the amount of PCB passing into
the estuary will continue to decrease with time. Also, it is
expected that, at the wqrst, the PCB concentration of previously
deposited sediments will remain at current levels (about 3 ppm)
and the level of PCBs in fresh dredge spoils will decrease.
Furthermore, it has been shown by the "Final Environmental Impact
Statement on Federal Channel Maintenance Dredging" that dredging
plans for the next 10 years will not likely involve sediments of
greater than 1 ppm PCB concentration, and that maintenance dredging
is not expected to create significant environmental impacts.
In conclusion, while the no-action alternative cannot be
considered to provide fully adequate protection to human health
and the environment (due to the fact that several hundred thousand
pounds of PCBs would remain in the river subject to only partial
natural containment), both the modeling and sampling data collected
to date indicate a decreasing threat to public health and the
.environment. The lack of sufficient data to establish the fate
and transport of PCBs in the Hudson River prevents the Agency
from making a final determination of no-action. Additional
environmental data collection will continue during the interim
evaluation period on feasible and reliable alternatives. The
most feasible and reliable alternatives assessed by EPA (limited
and full scale hot spot dredging) would be likely to decrease
the level of risk somewhat. However, as is mentioned above, the
actual reliability and'effectiveness of current dredging techno-
logies in this particular situation is subject to considerable
uncertainty. For this reason the no-action alternative is
recommended at this time. This decision may be reassessed in
the future if, during the interim evaluation period, the reli-
ability and applicability of in-situ or other treatment methods
is demonstrated, or if techniques for dredging of contaminated
sediment from an environment such as this one are further developed.
For example, dredging on a more limited scale may be conducted
in the Hudson under the authority of §116 of the Clean Water
Act; techniques developed for dredging operations under more
favorable conditions at other Superfund sites may be applicable
to dredging in this situation. However, even if hot-spot dredging
technologies were more reliable, the estimated high cost of
dredging and disposal might rule these out based on Fund-balancing
considerations, especially given the moderate degree of risk
reduction which may be achievable.
To protect area residents, the proposed action also includes
a detailed evaluation of the Town of Waterford's water treatment
facilities. This would include a sampling program and a subse-
quent analysis of the treatment operation. The decision for
providing upgraded or alternative facilities could then be made.
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Even though existing data show little problem at Waterford.
there is a possibility that a threat could arise. The cost of
this evaluation is low ($120,000), and is justified to ensure
protection of the public.
Treated drinking water from the Waterford supply system
rarely exceeds 0.1 ppb of PCBs according to United States Geolog-
ical Survey (USGS) studies. Based on results of 35 samples
(collected by N.Y. State), the PCB concentration of Waterford
drinking water averages 0.06 ppb. No study of Waterford drinking
water has ever found PCB concentrations in excess of 1 ppb,
which is the maximum allowable exposure promulgated by the New
York State Department of Health (NYSDOH). However, analysis of
river water quality at Waterford indicates incidents where PCB
concentrations have exceeded 1 ppb, therefore, generating some
concern and thus a more thorough evaluation is needed. The
USGS has taken samples of the water before and after treatment
in the mid-1970's. Analysis of these historical data show that
concentrations of PCBs in the river water are greatest during
high flows and during low flows. Consistent with this, water
supplies at Waterford should be sampled during the spring, when
flows are highest and during August or September when flows are
at a low. The water should be sampled before and after treatment.
The sampling results will allow evaluation of the effectiveness-'
of the treatment facilities and show whether upgrading is required.
Remnant Sites
An alternative evaluation was performed consistent with the
procedures outlined previously. fncluded in the list of alter-
natives was an array of options that were initially reviewed in
the EIS. Of primary concern was the potential for direct contact
by the public with the PCB contained within the remnant sites.
This was found to occur via two pathways, one being direct physical
contact by being on the site and the other through an air vector
whereby PCBs migrating either through adherence to dust particles
or volatilization would reach bordering communities. A secondary
concern was the continuous discharge of PCBs from the remnant
sites into the river.
Based on the alternative assessment, three options were
determined to mitigate adequately the pathways for human exposure
through direct contact and volatilization, although the degree of
effectiveness differed among them. These three options also
either eliminated or limited the migration of PCB contamination
into the river.
The three alternatives selected for further analysis included;
o Complete removal of the remnant sites,
o Partial removal of the remnant sites, and
o In-place containment
-------
-li-
lt was found that complete removal of the remnant sites would
provide the most effective option for addressing PCBs and the
associated pathways of exposure. This option would provide for
the elimination of the direct contact pathway which is the major
health concern, and would eliminate leaching of PCBs into the
river from these sites.
In addition, this action would be consistent with current
TSCA requirements to provide secure facilities for PCB waste.
While TSCA PCB regulations would not require that this contamination
be removed, since the creation of the remnant sites preceded the
enactment of TSCA, the TSCA technical standards of the regulation
would generally call for PCBs to be disposed of in approved
landfills and not located in floodplain areas.
While this option would eliminate the long-term impact
associated with the PCBs, there may be some adverse short-term
impacts on public health. Any large-scale excavation action
will result in an increase in a PCB release to the air (This is
documented by past dredging operations where air concentrations
of PCBs rose from less than 1 ug/m^ to 9 ug/m^ during the
removal of remnant site 3A). In addition, a large number of
truck trips (40,000) would traverse residential areas, creating
a potential health hazard and disrupting normal activity.
Erosion and resuspension of PCBs into the river would also
increase during the removal operations.
A removal alternative would be most effective in eliminating
any possibility of future PCB exposure from the remnant sites.
An evaluation of the cost associated with such an action indicates
that initial capital cost would be in excess of $12,000,000,
based upon the availability of a secure landfill within the
study area. As mentioned previously, the possibility of a local
site being available is remote. A rough estimate of the additional
expense that would be required to transport and dispose this
material at a secure site (the closest being Niagara Falls)
indicates that $50,000,000 would be needed.
The second option is the excavation and off-site disposal
of the portions of the remnant sites contaminated with greater
than 50 ppm PCBs, and the in-place containment of the remaining
PCB-contaminated portions of the site. This option, like the
other two options, would eliminate the risk of direct contact
with PCB contamination in the remnant deposits (assuming the cap
is properly maintained) and by decreasing the amount and concen-
trations of PCBs contained would substantially reduce the amount
of PCBs migrating into the Hudson River via ground water (as
compared to alternative 3, described below), although unlike
alternative 1 it would not completely eliminate such discharges.
However, the second option poses the same problems as the total
removal option, in that it would require large scale excavation
which has the potential of releasing increased amounts of PCBs
into the air over a short period of time. Limited removal would
be less expensive (approximately $9,000,000) than alternative 1,
-------
- 12 -
but it would still be substantially more expensive than
alternative 3, especially in the absence of a secure disposal
area near the sites.
The third option assessed was in-place containment of the
PCB-contaminated remnants. This option was recommended over
excavation and off-^site disposal in the EIS prepared for these
sites. The originally proposed alternative envisioned the
complete isolation of the remnant deposits by construction of
impermeable walls or barriers and installation of clay caps.
As explained below, further analysis indicates that complete
isolation is neither feasible nor practical at these sites;
however, the amount of PCBs which may be discharged to the river
is relatively low, especially in the context of existing levels
of contamination in the river.
The remnant sites are located on the floodplain of the river.
Some of the contaminated sediments were found to be up to 15 feet
deep. Thus, it would be impossible to prevent the ground water,
which at this point is directly related to the river level, from
entering the contaminated sediments from the bottom (through the
soil). Isolation of the remnant sites hydrogeologically would
be very difficult without some form of bottom sealing using
impermeable materials. Bottom sealing has only been looked at
on a lab scale, and has not been demonstrated to be technolog-
ically achievable at this time.
Since the remnant sites could not be totally isolated from
ground water, there is no point in constructing impermeable
barriers around them, nor is there any point in installing a
clay cap. A soil cover using 18" of subsoil placed in 6" lifts
and a final 6" layer of topsoil would adequately achieve the
primary objective of eliminating direct public contact with the
contaminated materials while also substantially reducing infil-
tration (80 percent compared to 90 percent for a clay cap).
In addition, a rip/rap stabilization system upgraded above
the 100 year flood level will assure the integrity of the sites.
(See Addendum 1). Finally, the sites will be fenced and posted
to prevent public access. There is, however, the potential that
without proper maintenance and monitoring of these sites, PCBs
may become exposed and present a health risk.
Under the third option, the remnant deposits would continue
to provide a source of PCB migration, through ground water,
into the river system. However, while levels of PCBs migrating
from the site have never been measured, it is believed that the
bulk of the PCBs are locked up in the remnant materials, and
that the discharges into the river are at relatively .low levels.
In light of existing levels of PCB contamination in the river
system, it is believed that such discharges are not particularly
significant.
-------
- 13 -
Each of the options assessed would be effective in mitiga-
ting or eliminating the threats to human health from direct
contact and volatilization. In-place containment would address
this concern for a cost of $2.3 million, substantially less than
the other two options. Options 1 and 2 would also eliminate or
reduce the migration of PCBs into the river system through ground
water. However, both excavation options pose a similar risk of
a short-term increase in the release of PCBs, and both are sub-
stantially more expensive than option 3. Given this substantial
additional expense, it is important to assess the utility of
eliminating this small source of PCB release. But this is
difficult to determine, pending an ultimate decision on whether
and how the contaminated sediments will be addressed. Therefore,
because in-place containment is the least expensive option that
effectively mitigates the direct contact threat and because the
merits of excavation cannot be adequately assessed based on
current information, in-place containment is the recommended
remedial option for the remnant sites at this time. The appro-
priateness of further remedial action for these sites will be
reexamined if EPA decides at a later date to take additional
action with respect to sediments in the river.
PCB Disposal Alternatives:
In order to assess the costs of each of the dredging/remnant
excavation projects discussed above, an evaluation was performed
which reviewed available PCB disposal options. These included a
range of options from placement in a secure landfill to detoxifi-
cation/destruction techniques. While the new technological
options were appealing, the limited historical data available
were sufficient to conclude that these alternatives would be
unreliable at this time, but quite promising in the future.
An analysis of remaining alternatives was then undertaken with
the following two assumptions:
o for all options, dredging of PCB hot spot
sediments/remnant sites would be performed, and,
o a site would be provided by N.Y. State within the study
area that would by acceptable as a secure landfill for the
PCBs.
The most effective disposal option available was determined
to be incineration since it would provide almost complete destruc-
tion of the PCBs. However, the capital costs associated with
constructing a multi-incinerator system that would have the
capacity to handle the massive amounts of PCB sediments would
be quite large, approximately $250,000,000.
A wet air oxidation process which could be applied to the
removed sediment was also found to be effective, but would
require extensive land area during operation. The capital cost
for this option would be higher than incineration.
-------
- 14 -
While the two alternatives discussed above were found to be
the most effective in containing and/or removing the harmful
aspects of PCBs, their costs were a limiting factor.
EPA also evaluated the disposal of the PCB sediment in a
secure landfill, which satisfied the PCB regulations under TSCA.
This facility would be located within the study area and would
be effective in providing an adequate level of protection for
the public and the environment. The costs associated with such
an option would be approximately $20,000,000 and therefore would
represent the cost-effective alternative.
Note, these estimates assume that a containment site would
be available within the study area. Based on recent events the
likelihood of this occurring in the immediate future is remote.
With this in mind, a rough assessment of disposal costs at a
privately owned secure facility (the closest being CECOS in
Niagara Falls, N.Y.) indicates that, for 40 hot spots or approx-
imately 1,450,000 cu. yd. of material, costs in excess of
$120,000,000 could be anticipated. Transportation costs are not
included and would add an additional $90,000,000 to this figure.
Community Relations;
In October of 1982, EPA issued a Final Environmental Impact
Statement (EIS) on the Hudson River Demonstration Project. In
the December 1982 Record of Decision (ROD), EPA found that the
project should be considered for funding under CERCLA (Superfund).
See Attachment 2.
Under Superfund, the NUS Corporation was requested to prepare
a Remedial Action Master Plan (RAMP). During the development of
the RAMP, it was determined that the document contained all the
elements to be considered a feasibility study and it was renamed
such in order to accelerate the decision process on remediation
at the site.
The draft feasibility study was the subject of a public
meeting held in Albany in November 3, 1983 (Attachment 3). As a
result of comments at the meeting, the public commment period
(originally scheduled to run 30 days and end on November 7, 1983)
was extended through November 30, 1983.
Numerous comments were received from a broad range of public
and private concerns. Response to these commments is the subject
of a responsiveness summary prepared by EPA and its consultant,
NUS Corporation.
-------
- 15 -
Consistency with Other Environmental Laws;
The recommended alternative for the remnant sites has been
reviewed for consistency with regulations under TSCA governing
the handling and disposal of PCBs. The TSCA regulations do not
require that PCBs disposed^ (including PCB-contaminated soil) in a
landfill before February, *1978, be removed. However, the rules
provide that if PCB-contaminated soil is disposed, or if PCB
contamination is removed for disposal after that date, it must be
disposed of either by incineration or in a chemical waste landfill
which complies with the TSCA PCB regulations. If these regulations
were legally applicable to the remnant deposits, containment using
the methods described above would not meet those standards. For
example, the containment area is not located in low permeability
soil and does not include a synthetic liner; is not sufficently
above the ground water table, and is located in a floodplain
area. Full consistency with these TSCA standards is not being
achieved because in-place containment is intended as an interim
remedy to address the direct contact and volatilization threat
posed by the sites. The remedy is not intended to eliminate the
low levels of release of PCBs into the Hudson River.
Cost;
The following figures represent an estimate of the costs
associated with the proposed actions. It has been the decision
of the NYSDEC to take the lead on this project. The site has
been classified as a 90 percent federal and 10 percent State
cost-sharing site for remedial implementation activities.
Activi cy Capital Cost
Design of remnant sites containment (RD) $200,000
Implementation of remnant containment (RA) 2,230,000
Waterford water supply evaluation 120,000
State administration/management (12%) 310,000
($278,000 for construction)
TOTAL $2,950,000
-------
- 16 -
Federal Share
State Share
90% (RA)
$2,338,200
• •
$ 259,800
100% (RD)
352,000
e
Total
$2,690,200
$259,800
$2 ,950,000
The above figures for remnant containment are based upon
covering all sites with surface dimensions estimated from
existing data. Actual pre-design evaluation, however, may
result in a containment area somewhat smaller due to site
erosion or reevaluation of PCS levels.
Schedule:
Proposed schedules for the recommended activities have
been prepared (Figures 4 and 5).
-------
TABLE 3
REMEDIAL ALTERNATIVES AND COST COMPARISONS
HUDSON RIVER PCB SHE. NEW YORK
Remedial Alternative
1. Delon. of Sediments with KOHPEO
2. Wet air oxidation of sediments
3. Incineration of sediments
4. Secure landfill disposal of sediments
5. Dredging of 40 hot spots
6. Reduced scale dredging
7. No remedial action, water supply not treated
8. No remedial action, water supply treated
B. Total removal of all remnant deposits
10. Partial removal of remnant deposits
11. Restricted access to remnent deposits
12. In-place containment of remnant deposits
13. tn-sltu detoxification of remnant deposits
14. No action on f 1, 2. &4/restrlcl access to
f 3 ft 5
IS. Partial removal/contaminant of remnant deposits
IB. Pertlal removal/restricted access of remnant deposits
17. Partial containment/restricted access to
remnant deposlta
18. Partial contamment/tn-sltu detoxification of
remnant deposits
1B. Partial removal/ln-sltu detoxification of
remnant deposits
20. Partial detoxification/restricted access of
remnant deposits
Capital Costs
$289.877.000
$109.340.000
$249.787.000
IS.203.000
54.987.000
34.048.000
120.000*
114.000
12.894.000
6.917.000
372.000
2.324.000
66.696.000
154.000
9.010.000
7.144.000
$ 1.053.000
$ 38.878.000
$ 42.822.000
$ 38.853.000
OB.M Costs
B
B
B
1.887.BOO
S.321.000
5.321.000
3.434.BOB
3.617.BOO
1.887.000
3.011.000
1.124.000
1.124.000
B
1.124.BOO
3.Oil.BOB
3.011.000
$ 1.124,000
$ 1.124.000
$ 1.887,000
$ 1.124.BOB
Total Costs
$289.877.BOO
$109.340.BOO
$249.787.000
17.090.BOO
60.308.000
39.369.000
3.434.000
3.731.000
14.781.000
9.928.000
1.498.000
3.406.000
66.696.000
1.278.000
12.021.000
10.155.000
$ 2.177.000
$ 40.002:000
$ 44.509.000
$ 37.977.000
•Includes Proposed Treatablllty Study
-------
-2-
The draft feasibility study will be available for a three .
public ceMMnt period as toon as the finishing touches are placid
on the document. We expect public release before October 7, 1983
After analysis of public comments, a final remedy under CERCLA
be selected for design and impl•mutation.
it appears that CERCLA funds nay not be available
for the dredging project, I have decided to consider an application
under section 116 for a PCB demonstration project. The State ojt,
New York should prepare an application sufficient to eeec all of
the statutory requirements set out in section 116. :T*o of the
requirements which are of particular concern to ne art this- point
are the availability of a secure landfill site, and better jJata .
defining the location of the significant bottom sediment areas.
As you know the State of New York was recently directed to revoke
the State permits for the secure landfill site previously selected.
Further, recent EPA sampling of the PCB contaminated sediments
in August 1983 indicates the location of the areas may have
shifted since the last sampling was done in 1977. 1 am willing
to consider a PCB dredging project for funding when these two
natters are resolved.
The potential problem of the authority and funds available..
under section 116 expiring on September 30, 1983^4was alleviated
on September 23, 1983 when a consent order was issued in the
lawsuits where the Agency's prior decisions to proceed under
CCftCLA on the PCB project are being challenged. In those suits,
brought by several environmental groups* Congressman Richard
Ottinger and the State of New York, I have agreed to a court
order deferring the expiration date of the authority to expend
funds under section 116(b). This order should give us the
opportunity to insure that the intent of Congress is carried
out.
The Agency shares your concern that this matter be acted
on as soon as possible. We are ready to proceed promptly toward
implementing the appropriate measure to solve problems caused
by PCBs in the Hudson River*
^.~.
Sincerely y&ors,
William D. Ruckelshaus
-------
[ATTACHMENT 1
* UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
' WASHINGTON. D.C' 20460 r*
9
Because of the continued interest in the PCB reclamation
project in the Hudson River, I am writing to advise you of toy
resent intentions concerning that project.
In our July 26, 1983 meeting and my subsequent letter to
iou, I indicated that EPA was conducting an evaluation of possible
Iternative remedial actions which could he undertaken to mitigate
he PCB contamination problem in the Hudson Kiver. The Agency has
eceived the preliminary results of its feesibi^ty study which
ncoroorated the data developed in our October 1982 Envircnmuntal
mpact Statement (EIS) and an additional analysis of cost-efiecti
:lternatives.
The draft feasibility study considered 36 alternative
Cleanup plans including a number of new PCB treatment and
destruction technologies. All reasonable alternatives were
considered.* The recommendations in the draft study indicate that
the only cost-effective actions that should be considered for
funding under the Comprehensive Environmental Respcna*, Compen-
sation and Liability Act (CERCLA) are (1) the containment of
exposed deposits of polychlorinated biphenyls (fCBs) at five
contamined areas along the shoreline of the Hudson River and
(2) the evaluation of drinking water supplies atwaterford,
New York to determine if PCB contamination poses any potential
threat to the public. Preliminary estimates are that the
shoreline project would cost approximately SI.8 million.
The study also concluded that the dredging of bottom
sediments, whose PCB concentration is greater than 50 parts per
million, is not cost-effective because: (1) the lack of a defined
threat to public health, and (2) the difficulty in showing that
significant environmental and public health benefits would result.
-------
TABL£ 2
Estimated Mass of PCB in the Hudson River Basin
Associated with Ganeral Electric Plants
Near Fort Edward, New York
UPPER HUDSON RIVER BASIN
Remnant Deposits 46,820 - 108,600 pounds1
Thompson Island Pool Sediments2
Hot Spots 97,700 - 105.800
Cold Areas 22,000-30,900
Remaining Upper Hudson Pools
Hot Spots 60,600-64,100
Cold Areas 101,400 - 146,400
Subtotal, Upper Hudson River Sediments Only
Hot Spots 158.300 - 169,900
Cold Areas 123.400 - 177.300
281,700 - 347.200
Dredge Spoils 103,455 - 160,000
Dumps 528,000 - 745,000
Subtotal, Upper Hudson Basin Only 959.975 - 1.360.800
LOWER HUDSON RIVER BASIN
Sediments 169,000 - 200,000
Dredged 86,000
Washed out to sea 200,000
TOTAL PCB 1.414,975 - 1 .846.800
1 Remnant deposit totals do not include estimates for area 3A.
2 Thompson Island Pool totals include estimates for sediments above Lock 7.
Sources: Bopp et al. 1978
• Hetling et al. April 1978
Tofflemire and Quinn 1979
Malcolm Pirnie 1980
2-2
-------
TABLE 1
PCS CONTAMINATION IN REMNANT DEPOSITS
Remnant
Area
1
2
3
3a
4
4a
5
Total
Area
(acres)
4.0
8.0
13.3
6.0
12.0
8.5
55 .'8
Avg. PCB
Cbnctntration
(pom)
20
5
65
1000
25
40
250
Contaminated
Depth
(ft)
2
5
8
1
2
3
8
Contaminated
Volume
(vd3)
12,900
64,530
160.925
9.680
38,720
41.140
31.630
359,525
Less Area 3a
Remaining
Source: (Tofflemire, 1980).
PCB
Mass
m
450
570
18,550
17,000
1700
2900
22.650
63,820
17.000
46.820
4-9
-------
WMNANT «MA 4
•OlOO-v/
NEMNANT MtA I
10*00
SARATOGA COUNTt
COVERED n THE IOO VEAN FLOOD
LIMIT OF IOO YEAR FLOOD STAGE
PLAN VIEW, REMNANT DEPOSITS
HUDSON RIVER PCB
FIGURE
IMUS
CORPORATiaN
A Halliburton Company
-------
c.
(Source-Malcolm Pirnle Sept. 1980)
PROJECT AREA
LOWER HUDSON
HUDSON RIVER PCB SITE, HUD
SCALE' l"= 16 MILES
IVER. NY
FIGURE 2-
rs
-------
ALBANY CO
ALBANY
MO
RENSSELAER CO.
(Soured - Malcolm Pirni«, Sept. I960)
WARREN CO.
WASHINGTON CO.
FORf
EDWARD
J:/X GLENS
\--/ FALLS
HUDSON
FALLS
PROJECT AREA
UPPER HUDSON
HUDSON RIVER PCB SITE. HUDSON RIVER. NY
NOT TO SCALE
FIGURE |
IMUS
A Halliburton Company
-------
-1-
ADDENDUM 1
Hudson River PCBs Site
New York
FLOOD PLAIN MANAGEMENT ASSESSMENT
• •
I. Purpose
The purpose of this addendum is to:
1. Review Executive Order No. 11988, May 24, 1977, 42
F.R. 26951 entitled Floodplain Management;
2. Review applicable status referred to in the Executive
Order as required;
3. Review the proposed remnant, site contaminment option
as it relates to the floodplain of the Hudson River;
4. Summarize the review and describe any technical
requirements necessary to comply with (1) and (2)
above.
II. Introduction
A feasibility study was prepared by NUS Corporation, EPA's
consultant, which evaluated alternatives to remediate the
PCB contamination at five (5) remnant sites located in
the Upper Hudson River floodplain. Thuse remnant sites
were formed when the Fort Edward Dam was removed in 1973
leaving more than 1.5 million cubic yards of contaminated
sediments in five discrete deposits exposed along the
edges of the river in a 1.5 mile stretch upstream of Fort
Edward. The locations of these remnant deposits are
illustrated in Fiqure I. A large percentage of the PCBs
have been scoured and transported downstream. In addition,
some have been removed through prior dredging. Approximately
10 percent of the total PCBs remain.
The remnant deposits contain high amounts of sawdust, wood
chips, and other debris remaining from a once thriving
lumber industry.
The most highly contaminated sediments were generally
found in the top few inches of sample cores? however,
significant contamination extended up to 10 feet below
the surface. PCB levels ranged from 5620 ppm at the
surface of a core from site 3a to less than 3 ppm, which
was commonly .found a few inches deep in many samples.
PCB concentrations tended to increase with distance from
the edge of the present below bank. This trend is
characteristic of the river below the remnant deposits
and is related to velocity distributions and sediment
characterisitics as will be discussed later.
-------
-2-
The remanant deposits were subjected to a number of remedial
activities between 1974 and 1978, the most significant of
which was the excavation and containment of remnant area 3a.
The unstable banks of areas 3 and 5 were graded and stabilized
with stone riprap and these areas, along with area 2 were
revegetated. An aerial Inspection in 1983, however, revealed
that the plantings had not taken well. Remnant deposit 1,
which is an island, had not been subjected to any remedial
action. The aerial inspection in 1983 showed it to be much
smaller than before.
Ninety percent of the time, the river surface elevation is at
or below the lower boundary of significant PCB contamination
within the remnant deposits (Malcolm Pirnie, Inc., 1978).
Thus, bank scour during periods of high flow is the principal
mechanism responsible for the transfer of PCBs to the lower
reaches.
Infiltrating rain water and runoff, as well as groundwater
movement, carry some desorbed PCBs to the river; however,
this contribution is insignificant compared to the PCB load
passing Rogers Island. Remnant deposit saturation during
floods would not contribute significant amounts of PCBs to the
river since the hydraulic gradient would slope away from the
river during these periods and desorbed PCBs would be carried
inland where they would be attenuated by soil particles.
Malcolm Pirnie, Inc., (1978) estimated that approximately
8600 pounds of PCB per year were lost to the river from the
remnant deposits before remedial activities were implemented.
Tofflemire and Quinn (1979) suggested that after remediation,
the unstable bank areas of remnant deposit 4 presented the
greatest potential for future erosion losses. The most highly
contaminated desposits, areas 3 and 5, are not likely to
erode because they are adequately protected against flows
substantially higher that the average annual flood.
Figures II through VI depict typical cross sections at the
remnant deposits and relate contaminated materials and remedial
construction features to river stages.
-------
-3-
Inscribed on these figures are the values for the average
annual and 100 year flood elevations. The following table
illustrates the current situation. It is important to note
that the figures are based on data accumulated in 1977 and
since then erosion and runoff may have altered the dimensions
of the remnant areas.
Elevation (feet above
mean sea level)
Remnant
Site
1
2
3*
4*
5*
1977
Site
134
>137
>132
>132
>130
Average
Annual
Flood
133
,133
130
133
127
100
Year
Flood
137
138
134
133
130
*Site partially riprapped
These sites are basically in pool type areas of the Hudson
River where flow vectors would be less than in the main
channel of the river.
Ill. Proposed Site Remedial Action
The selected remedial action for the remnant deposits
is in-place containment. These areas will be covered
with an 18 inch thick layer of subsoil followed by a
6 inch layer of topsoil. The cover will then be graded
and seeded to minimize erosion and, in appropriate
"" areas, raised to ensure the integrity of the site.
Where necessry, bank stabilization will be performed
along the riverbank in the form of riprap. Fencing
and posting will be placed, where necessary, to
restrict public access.
-------
IV. Flood Plain Regulatory Requirements
In accordance with Executive Order 11988, Floodplain
Management, an applicable executive agency shall
provide leadership and shall take action to reduce the
risk of flood loss, to minimize the impact of floods on
human safety, health and welfare, and to restore and
preserve the natural and beneficial values served by
floodplains. In addition, it is necessary to evaluate
the potential effects of any action that may be taken
in a floodplain and that potential harm is minimized.
The following agencies would be involved in any floodplain
management efforts:
o United States Environmental Protection Agency
o U.S. Army Corps of Engineers
o Federal Emergency Management Agency
o New York State
- Department of Environmental Conservation
- Department of Transportation
o Town and Villages bordering on the Hudson River.
As a responsibility under the cooperative agreement .
between the USEPA and the NYSDEC the appropriate
agencies and concerned groups will be kept abreast of
proposed design design and construction activities.
The EPA in conjunction with the NYSDEC has determined
that the proposed activities for the remnant sites are
the most practical option available in light of current
funding limitations and technical constraints. An
option that was evaluated as being the most-effective
in removing the PCB vectors would require complete
removal of the remnant sites. If this option were
implemented, the floodplain upstream would result in a
" ""larger cross-section. It must be pointed out that
major charges in the floodplain were incurred as a
result of the removal of the Fort Dam in 1973, since
the levels of river water decreased upstream.
V. Flood Hazard Assessment
The flood hazard associated with this project would be in
the upstream effects of introducing trill material onto
the remnant sites. The proposed action would provide a
soil cap on the remnant sites as well as securing the
banks to contain PCBs at the sites and deter erosion into
the river, as well as, eliminating the direct human
contact vector.
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-5-
Based upon the data available, which are depicted in the
attached figures, the amount of fill necessary to raise
the sites above the 100 year flood level is insignificant
since the majority of the remnant sites are currently above
the flood elevation. There should therefore be insignificant
adverse impacts on the surrounding environment during
flooding.
The design of the proposed action will incorporate erosion
control in the form of
o Riprap shoring of banks
o Vegetative protection
o Future maintenance
The beneficial effects on the human environment and the
river ecosystems by containing/controlling this PCS source
greatly outweigh the minimal if any impacts on the 100
year floodplain by the proposed action.
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MMNANT AM* 4
•O»OO-v/-"^ -
MMNANT AM A I
SARATOGA COUNTY
COVIMO BV TMf 100 VKAN FLOOD
;•""'> LIMIT Of 100 YEAR FLOOD STAGE
FIGURE I
PLAN VIEWj REMNANT DEPOSITS
HUDSON RIVER PCB SITE. HUDSON RIVER. NY
SCALE' I = 2,000
IMUS
__LJ OCDRPORAT1DN
-------
WEST
EAST
160
UJ
u.
UJ
UJ
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ay
I4O
£
o
S 130
UJ 12° 0
100 YEAR FLOOD
8ROUNO SURFACE
AVO. ANNUAL FLOOD
90% DURATION FLOW
AVO. CONTAMINATED DEPTH
200
DISTANCE (FEET)
400
SOURCE' TRANSECT 92+OO, MALCOLM PIRNIE (1977)
TYPICAL CROSS SECTION AT REMNANT DEPOSIT 1
HUDSON RIVER PCB SITE. HUDSON RIVER. NY
FIGURE
VIIMUS
I nORFCWAnarvJ
A Haftburibn Company
-------
Ul
WEST
fc
UJ
u.
UJ
UJ
CO
UJ
g
ISO
140
130
UJ
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UJ
120
AVO. CONTAMINATED
DEPTH
EAST
GROUND SURFACE
^ AVO. ANNUAL FLOOD
EXISTING BANK
BANK BEFORE MARCH 1976
„„ FLOOD
200
DISTANCE (FEET)
400
SOURCE1 TRANSECT 80+OO, MALCOLM PIRNIE (1977)
TYPICAL CROSS SECTION AT REMNANT DEPOSIT 2
HUDSON RIVER PCB SITE, HUDSON RIVER, NY
FIGURE
IIMUS
r
CCJRPORATIDN
A Halliburton Company
-------
WEST
EAST
UJ
UJ
UJ
UJ
UJ
CO
o
at
146
135
125
_
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IIS
ASSUMED TOP OF STONE
RIP-RAP
0 ROUND SURFACE
AVO. ANNUAL FLOOD
AVO. CONTAMINATED DEPTH
200
DISTANCE (FEET)
400
SOURCE- TRANSECT S244O, MALCOLM PIRNIE (1977)
TYPICAL CROSS SECTION AT REMNANT DEPOSIT 3
HUDSON RIVER PCB SITE, HUDSON RIVER, NY
FIGURE* TCT
PHIMUS
_LJ CORPORATOr
-------
WEST
EAST
**!
UJ
2
UJ
UJ
o
145
135
125
UJ
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115
GROUND SURFACE
AVG. CONTAMINATED
DEPTH
I ASSUMED TOP OF STONE
RIP-RAP
AVO. ANNUAL FLOOD
90% DURATION FLOW
20O
DISTANCE (FEET)
400
SOURCE' TRANSECT 2O»OO, MALCOLM PIRNIE (1977)
TYPICAL CROSS SECTION AT REMNANT DEPOSIT 4
HUDSON RIVER PCB SITE, HUDSON RiVER. NY
FIGURE
IMUS
CXDRPORATION
if A Hallkburion Company
-------
o>
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en
O
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g
1
ui
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Ul
WEST
EAST
145
135
125
115
GROUND SURFACE
ASSUMED TOP OF STONE
RIP-RAP
100 YEAR FLOOD
90% DURATION FLOW
AVO. ANNUAL FLOOD
AVO. CONTAMINATED DEPTH
200
DISTANCE (FEET)
40O
SOURCE' TRANSECT 2+OO, MALCOLM PIRNIE (1977)
TYPICAL CROSS SECTION AT REMNANT DEPOSIT 5
HUDSON RIVER PCB SITE, HUDSON RIVER. NY
FIGURE -V-L-
IMUS
CORPORATTOM
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\
?/EPA News Release
82(69) Call: Jim Marshall (212)264-2515
FOR RELEASEi Thursday, December 30, 1982
EPA WILL ADDRESS HUDSON RIVER PCBs THROUGH •SUPERFUND*
The U.S. Environmental Protection Agency (EPA) today announced that it
will not use the Clean Water Act to fund a demonstration project to remove Hudson
River sediments from Albany north to Fort Edward that are contaminated
with polychlorinated biphenyls (PCBs). Instead, EPA Administrator Anne M. Gorsuch
has determined that the problem should be addressed by means of the Comprehensive
Environmental Response, Compensation and Liability Act (CEHCLA, or "Superfund").
Section 116 of the Clean Water Act required the Administrator to determine whether
funds are available from sources other than the Clean Water Act, including
Superfund.
This means that more than $18 million in Federal sewage treatment funds
that had been set aside for the PCB project will now become available for
sewage projects in Mew York State.
Today's action is the final step in an environmental impact analysis
process to evaluate a demonstration project authorized by Section 116 of
the Clean Water Act. In the $26.7 million project only 30 to 35% of the
contaminated sediments would be selectively removed and disposed of in a
secure landfill in Washington County.
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-2-
Jacqwelina 8. Scbrnfmr, DA'S regional administrator la Sew York, pointed
out that •thl» extaamiiej analysis ha« failad to persuade WA that the partial
dredging projact would significantly banafit tha Hudaon Rlvar fishery, ineraaaa
tha protaction of drinking watar or raduea tha riak of PCS contamination
south of Albany.'
* *-• -,
•Howaver," aha added, *wa believe enough concern still exists about tha
potantial for futura contamination of drinking water or exposure of tha
* * — - • . ^
public to tha contaminated raonant dapoaita at Port Edward to warrant a
further look under CBC1A."
K preliminary calculation by EPA ahowa that tha Hudaon River KB problem
would acore high enough for ineluaion on tha propoaad CEPCLA National
Priority Liat of aitaa for poaaibla action. It is anticipated that the
site will be added shortly after tha proposed list becomes final. Inclusion
of the site on tha list will trigger tha following actions (most of the
neaded data and studies were developed during the environmental impact analysis)
• Preparation of a Remedial Action Master Plan {RAMP) to determine
whether initial steps to protect the public health are required and
whether additional monitoring ot sampling is needed;
• A search to identify responsible parties;
• Preparation of a feasibility study addreaaing such questions as
whether any threat could be mitigated by controlling tha remnant deposits,
whether off-site remedial action may be required because of continued
migration of PCBs, and what alternative actions (including no action)
may be feasible and coat affective.
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-3-
Zf a Superraad-fiMneejd action is found to be appropriate, a fond-balancing
i
analysis »u«t be> perforaed to ensure th* action would provide a cost-
effective response that balances the need to protect public health and the
environaent at this site with the availability of Soperfund dollars to
• *
respond to other sites.
Consistent with EPA policy, the agency will also initiate enforcement
Measures to pursue a privately funded response to the problea. These
aeasures may include a search to identify responsible parties; notice to
these parties that Superfund action may be taken and an opportunity, through
negotiation, for then to undertake the action; or other appropriate enforcement
measures.
If Superfund monies are used, state cost sharing is required.
Copies of today's determination and EPX's Recdrd of Decision are being
mailed to all interested parties.
It*
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N.Y, 10007
EPA
News Release
83(96) James Marshall (212) 264-2515
FOR RELEASE: October 13, 1983
EPA SCHEDULES PUBLIC MEETING ON PCBs IN THE HUDSON RIVER
NEW YORK — The U.S. Environmental Protection Agency (EPA)
has scheduled a public meeting to discuss the draft feasibility
i
study which looks at alternative remedies for the problem of
Hudson River sediments that are contaminated with polychlorinated
biphenyls (PCBs) above Albany, N.Y.
The draft feasibility study considered 36 alternative clean-
up plans including a number of new PC3 treatment and destruction
technologies. All reasonable alternatives were considered. The.
meeting will be held November 3rd, 1983 from 3:00 PM to 5:30 PM
and 7:00 PM to 9:00 PM in Meeting Room 1 on the Concourse Level
at Governor Nelson A. Rockefeller Empire State Plaza.
Copies of the study are available for public inspection and
review at the following locations:
NYS Department of Environmental Conservation (DEC)
202 Mamaroneck Avenue
White Plains, N.Y.
-more-
-------
DEC DEC, Division of Water, Rm. 201
21 South Putt Corners Rd. 50 Wolf Road
New palt*, N.Y. Albany, N.Y.
DEC Crandall Library
2 World Trade Center • City Park
Room 6126 Glens Falls, N.Y.
New York, N.Y.
The public comment period on the study opened on October
7th and is scheduled to close on 'November 7th.
All written comments and requests to speak at the public
meeting should be mailed to:
Robert Raab, Project Officer
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Region II
26 Federal Plaza, Room 402
New York, N.Y. 10278
***
-------
Ul
PRELUMNARV REMEDIAL MVESTKATION ACTIVITIES
TASK 1 - PREPARE Rl WORK PLAN
TASK I - PERFORM COMMUNITY RELATIONS
SUPPORT FUNC TUNS
TASK 1 - COLLECT AND EVALUATE EXISTING
DATA
TASK* - PERFORM HEALTH, SAFETY. AND
GENERAL SITE RECONNAISSANCE
TASK* - SECURE PERMITS, MGHT* OF ENTRY
AMD OTHER AUTHORIZATIONS
TASK* . PROCURE SUBCONTRACTORS
TASK; - DEVELOP SITE-SPECRTC HEALTH
AND SAFETY PLAN •
TASKI - DEVELOP SITE-SPEOFIC QUALITY
ASSURANCE PLAN
TASK* - DEVELOP SITE-SPECnC SAMPLING
PLAN
TASK 10 . M06R.IZE FIELD EQLNPMENT
SITE REMEDIAL INVESTIGATION ACTIVITIES
TASK II - PERFORM GROUND SURVEY
TASK II - PREPARE TOPOGRAPMC MAP f
' TASK 11 - COLLECT SURFACE SOIL SAMPLES
TASK 1* - REDUCE AND EVALUATE DATA <
TASKI) - PREPARE REMEDIAL INVESTIGATION
REPORT
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REMEDIAL INVESTIGATION PROJECT SCHEDULE. REMNANT DEPOSITS
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